603 U.S. 324
SCOTUS2024Background
- Idaho enacted a law (the Defense of Life Act) that prohibits abortions except when necessary to prevent the pregnant woman's death, with no exception for grave health risks.
- The U.S. sued Idaho, arguing that the federal Emergency Medical Treatment and Labor Act (EMTALA) preempts the Idaho law by requiring hospitals to provide emergency abortions necessary to stabilize a patient’s condition.
- A district court preliminarily enjoined Idaho’s law where it conflicted with EMTALA; the Ninth Circuit declined to stay the injunction.
- The Supreme Court granted a stay, heard oral argument, and granted certiorari before judgment to consider the case.
- After briefing and argument, the Court dismissed the writ of certiorari as improvidently granted and vacated the stay, allowing the injunction to remain while litigation continues in lower courts.
Issues
| Issue | Moyle/Idaho Argument | U.S. Argument | Held |
|---|---|---|---|
| Does EMTALA require hospitals to provide abortions prohibited by Idaho's law? | EMTALA does not override state abortion bans; it protects both woman and unborn child. | EMTALA preempts state law when abortion is necessary to stabilize a health emergency. | No definitive ruling; SCOTUS dismissed case as improvidently granted. |
| Are Idaho physicians at risk of criminal liability for performing emergency abortions? | Physicians are only protected if abortion is necessary to prevent death; not for preventing grave harm. | Criminal risk deters provision of required emergency care under EMTALA. | With stay vacated, injunction protects physicians while litigation continues. |
| Scope of EMTALA preemption over state law in Spending Clause context | Idaho never agreed to be bound by conditions overriding criminal law; ambiguous spending conditions can't preempt | Federal requirements for emergency care under EMTALA must supersede conflicting state criminal law. | No definitive ruling; Court leaves issue for lower courts to consider. |
| Whether procedural shifts or narrowing of parties’ positions mooted the Supreme Court’s review | Lower courts, not Supreme Court, should resolve newly clarified or narrowed factual and legal disputes. | EMTALA-ID ban conflict remains real and merits Supreme Court review now. | Writ dismissed as improvidently granted; case returned to lower courts. |
Key Cases Cited
- Dobbs v. Jackson Women’s Health Org., 597 U.S. 215 (overruled Roe v. Wade and returned abortion regulation to the states)
- Nken v. Holder, 556 U.S. 418 (standard for stay pending appeal)
- Pennhurst State School and Hospital v. Halderman, 451 U.S. 1 (conditions on federal grants under Spending Clause must be unambiguous)
- Mutual Pharmaceutical Co. v. Bartlett, 570 U.S. 472 (state laws that conflict with federal law are preempted)
- Gonzales v. Oregon, 546 U.S. 243 (federal statute’s intrusion into traditional state power must be clear and manifest)
- Maryland v. Louisiana, 451 U.S. 725 (Supremacy Clause renders conflicting state laws void)