Planned Parenthood South Atlantic v. Baker, 487 F.Supp.3d 443

Plaintiffs: Planned Parenthood South Atlantic (PPSAT) and Julie Edwards, a South Carolina Medicaid beneficiary who received care at PPSAT’s Columbia clinic. PPSAT provided family‑planning and preventive services to Medicaid patients (it also performs abortions, which Medicaid generally does not cover).
Defendant: Joshua Baker, Director of the South Carolina Department of Health and Human Services (SCDHHS), terminated PPSAT’s Medicaid enrollment after gubernatorial executive orders directing agencies to exclude providers affiliated with abortion clinics.
Legal claim: Edwards sued under 42 U.S.C. § 1396a(a)(23)(A) (the Medicaid Act free‑choice‑of‑provider provision) and § 1983; she sought declaratory and injunctive relief.
Procedural history: The district court previously granted a TRO and preliminary injunction; the Fourth Circuit affirmed. Plaintiffs moved for summary judgment on Count One (Edwards’s § 1983 claim enforcing the Medicaid Act).
Key factual/legal findings: SCDHHS did not contend PPSAT provided substandard care; the record contains no dispute that PPSAT was otherwise qualified under the Act. The termination was motivated by PPSAT’s provision of abortion‑related services outside Medicaid.
Disposition: The court granted summary judgment for Edwards on Count One, declared SCDHHS’s termination void, and issued a permanent injunction preventing termination of PPSAT from Medicaid based on lawful abortion‑related services.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination violated the Medicaid Act free‑choice‑of‑provider provision	Edwards: terminating PPSAT for lawfully providing abortion‑related services to non‑Medicaid patients unlawfully denies beneficiaries’ right to choose a qualified provider	Baker: termination permissible; various procedural and substantive defenses (waiver via enrollment agreements, exhaustion, ripeness, standing) and challenges to Fourth Circuit precedent	Court: Held termination violated § 1396a(a)(23)(A); granted declaratory relief and permanent injunction
Whether the Medicaid free‑choice provision creates a private right enforceable under § 1983	Edwards: she can enforce the provision via § 1983	Baker: contends Fourth Circuit precedent is wrong	Court: Followed Fourth Circuit (Baker II) — a private right exists under § 1983
Standing and ripeness	Edwards: she suffers injury and claims are ripe (deprivation of statutory right to chosen provider)	Baker: argued lack of injury/ripeness	Court: Reaffirmed prior holdings that Edwards has standing and claims are ripe
Whether summary judgment was premature and discovery required	Edwards: the dispute is primarily a question of law; summary judgment appropriate without further discovery	Baker: record is incomplete; discovery/mediation should proceed	Court: Found no genuine dispute of material fact on Count One and legal questions controlled; denied need for further discovery and granted summary judgment

Planned Parenthood S. Atl. v. Baker, 326 F. Supp. 3d 39 (D.S.C. 2018) (district court’s TRO and preliminary injunction ruling affirming injury and need for relief)
Planned Parenthood S. Atl. v. Baker, 941 F.3d 687 (4th Cir. 2019) (holding the Medicaid free‑choice‑of‑provider provision creates a private right enforceable under § 1983)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard; burden shifts where nonmoving party lacks evidence on essential element)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (standard for genuine dispute of material fact at summary judgment)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (nonmoving party must do more than raise metaphysical doubt to avoid summary judgment)
Perini Corp. v. Perini Constr., Inc., 915 F.2d 121 (4th Cir. 1990) (view evidence in the light most favorable to the nonmoving party)
United States v. Aramony, 166 F.3d 655 (4th Cir. 1999) (law‑of‑the‑case doctrine)