Yolanda Martes v. Chief Executive Officer of South Broward Hospital District, 683 F.3d 1323

Plaintiffs are Florida Medicaid ‘medically needy’ beneficiaries who allege improper balance billing by SBHD and other hospitals; AHCA and DCF allegedly failed to supervise/enforce compliance with balance billing provisions.
The district court dismissed Count I (federal §1983 claim) for lack of an individual right under 42 U.S.C. §1396a(a)(25)(C) and declined supplemental jurisdiction over state-law counts II–IV.
The amended complaint alleges violations of §1396a(a)(25)(C) and a Florida statute; plaintiffs seek damages and injunctive relief.
§1396a(a)(25)(C) requires State plans to prohibit balance billing when a third party is liable for payment.
The district court held §1396a(a)(25)(C) does not create an individual federal right enforceable under §1983; court declined to exercise jurisdiction over state-law claims.
On appeal, the Eleventh Circuit affirms the district court’s disposition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does §1396a(a)(25)(C) create a private §1983 right?	Martes argues it creates an individual right to be free from balance billing.	SBHD/defendants argue the provision targets providers and third-party liability, not individuals.	No private right; statute focuses on provider conduct and state plans.
Is there rights-creating language under Gonzaga and Blessing for §1396a(a)(25)(C)?	The use of ‘individual’ signals an individual right.	Language is not rights-creating; focus is on providers and third-party liability.	Not rights-creating; no §1983 remedy for plaintiffs.

Blessing v. Freestone, 520 U.S. 329 (1997) (three-factor Blessing test for Spending Clause rights)
Gonzaga Univ. v. Doe, 536 U.S. 273 (2002) (limits private rights under §1983 to unambiguously conferred rights)
Arrington v. Helms, 438 F.3d 1336 (11th Cir. 2006) (modifies Blessing test for individual rights analysis)
31 Foster Children v. Bush, 329 F.3d 1255 (11th Cir. 2003) (rights must be explicit; mere use of 'individual' insufficient)
Wesley Health Care Ctr., Inc. v. DeBuono, 244 F.3d 280 (2d Cir. 2001) (contracting third-party liability; not create private right for providers)
Pennhurst State Sch. & Hosp. v. Alderman, 451 U.S. 1 (1981) (spending power enforcement is typically withdrawal of funds, not private action)
Gonzaga Univ. v. Doe, 536 U.S. 273 (2002) (emphasizes rights-creating language and individual focus)
Mallo v. Public Health Trust, 88 F. Supp. 2d 1376 (S.D. Fla. 2000) (pre-Gonzaga reliance; distinguished by Gonzaga)