Supreme Court rules against Planned Parenthood over Medicaid
Ruling limits Medicaid patients’ ability to sue states over provider access, leaving enforcement to federal agencies.
The U.S. Supreme Court issued a decision that could reshape how Medicaid patients challenge restrictions on their healthcare access.
On Friday, the court ruled that individuals cannot sue state officials under federal civil rights law to enforce a Medicaid provision that allows patients to choose their healthcare providers. The 6-3 ruling in Medina v. Planned Parenthood South Atlantic reverses a lower court decision. It marks a significant setback for Planned Parenthood and Medicaid beneficiaries in South Carolina who sought to block the state’s exclusion of the reproductive health care provider from its Medicaid program.
Writing for the majority, Justice Neil Gorsuch said the Medicaid statute’s “any-qualified-provider” provision does not create an individual right enforceable through private lawsuits. Instead, the Court found, the provision is part of a contract-like arrangement between states and the federal government, enforceable primarily by federal officials through the threat of withholding Medicaid funds, not by individual beneficiaries.
The case originated after South Carolina barred Planned Parenthood from participating in its Medicaid program in 2018, citing a state law that restricts public funding for abortion services. Planned Parenthood, which provides a wide range of health services beyond abortion, argued that the move violated a federal Medicaid requirement that states must allow patients to seek care from any provider “qualified” to perform the service.
Lower courts sided with Edwards and Planned Parenthood, concluding that the Medicaid provision at issue created an individual right that could be enforced through Section 1983 of the Civil Rights Act.
The Supreme Court disagreed. The majority ruled that the Medicaid statute lacked the kind of explicit, rights-creating language required to support private lawsuits.
The decision narrows the path for Medicaid patients who wish to challenge state decisions regarding which providers participate in the program, leaving enforcement of provider access primarily in the hands of federal agencies.
Justice Ketanji Brown Jackson, writing in dissent, warned that the ruling could effectively bar patients from holding states accountable for violating Medicaid guarantees. Joined by Justices Sonia Sotomayor and Elena Kagan, Jackson argued that the majority’s reasoning “hollows out” patients’ ability to challenge restrictions that could limit their health care options.
The ruling is likely to have ripple effects beyond South Carolina, potentially emboldening other states to exclude certain providers without fear of immediate legal challenges from patients. It also underscores the Court’s continuing shift toward limiting private enforcement of federal statutes, particularly those tied to federal funding agreements with states. If Congress wishes to provide other avenues of enforcement, Gorsuch wrote, “it can create new ones.”