Medina v. Planned Parenthood South Atlantic
| Medina v. Planned Parenthood South Atlantic | |
|---|---|
 | |
| Argued April 02, 2025 Decided June 26, 2025 | |
| Full case name | Medina v. Planned Parenthood South Atlantic |
| Docket no. | 23-1275 |
| Citations | 606 U.S. (more) |
| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| Case history | |
| Prior | Kerr v. Planned Parenthood South Atlantic, 599 U.S. __ (2023). |
| Holding | |
| Section 1396a(a)(23)(A) of the Medicaid Act does not clearly and unambiguously confer individual rights enforceable under . | |
| Court membership | |
| |
| Case opinions | |
| Majority | Gorsuch, joined by Roberts, Thomas, Alito, Kavanaugh, Barrett |
| Concurrence | Thomas |
| Dissent | Jackson, joined by Sotomayor, Kagan |
| Laws applied | |
| The Medicaid Act, 42 U.S.C. §§ 1396a and 1983 | |
Medina v. Planned Parenthood South Atlantic, 606 U.S. __ (2025),[a] is a United States Supreme Court case in which the Court held that the Medicaid Act does not give individuals an enforceable right to choose a specific healthcare provider.[1]
Background
The federal Medicaid program, established in 1965, provides medical care, in collaboration with the states, to low-income individuals. Federal funding for Medicaid cannot generally be used for abortions. In 2018, South Carolina Governor Henry McMaster issued Executive Order 2018-21, which ordered South Carolina Department of Health and Human Services to deem abortion clinics "unqualified" to provide family planning services under Medicaid.[2] Julie Edwards, one of the patients of Planned Parenthood South Atlantic, joined by Planned Parenthood, sued Robert Kerr, the director of South Carolina Department of Health and Human Services, arguing the order violated the federal civil rights law that allows Medicaid patients to get care from any "qualified" provider of their choice.[3]
The district court entered a permanent injunction preventing South Carolina from excluding Planned Parenthood from its Medicaid program. On appeal, the U.S. Court of Appeals for the Fourth Circuit affirmed the district court's decision and held that the Medicaid Act creates individual rights that can be enforced under federal civil rights law.[4][5]
The Supreme Court vacated the Fourth Circuit's decision and remanded for further proceedings. The Fourth Circuit reaffirmed the district court's decision.[5]
Opinion of the Court
The Supreme Court heard oral arguments on April 2, 2025.[6]
The Supreme Court ruled in 6-3 decision reversing the lower court's decision. Justice Neil Gorsuch, wrote the majority opinion, which says "Congress knows how to give a grantee clear and unambiguous notice that, if it accepts federal funds, it may face private suits asserting an individual right to choose a medical provider."[7][8] Under civil rights law, individuals can sue when their legal rights are violated, but they can only sue when federal spending power statutes are violated in "atypical situations." While the Medicaid Act's "any-qualified provider" rule provides that Medicaid patients can choose any eligible provider, the Court ruled this does not clearly and unambiguously grant individuals the right to sue, so private lawsuits cannot be brought under this provision.[5][9]
Justice Thomas filed a concurring opinion.[5]
Justice Ketanji Brown Jackson, wrote the dissenting opinion, arguing that it violated Civil Rights Act of 1875 that allow people to sue for their civil rights violations.[5]
Notes
- ^ The case was previously known as Kerr v. Planned Parenthood South Atlantic. It became Medina v. Planned Parenthood South Atlantic following the replacement of Robert Kerr, the director of South Carolina Department of Health and Human Services
References
- ^ Chung, Andrew (2025-06-26). "US Supreme Court backs South Carolina effort to defund Planned Parenthood". Reuters. Retrieved 2025-07-13.
- ^ "Office of the Governor - Executive Order No. 2018-21" (PDF). governor.sc.gov. July 13, 2018. Retrieved August 13, 2025.
- ^ Howe, Amy (2025-04-01). "Supreme Court considers South Carolina's effort to strip Planned Parenthood of Medicaid funding". SCOTUSblog. Retrieved 2025-07-13.
- ^ Pierson, Brendan (2024-03-06). "South Carolina still cannot defund Planned Parenthood, US court rules". Reuters. Retrieved 2025-07-13.
- ^ a b c d e "Medina v. Planned Parenthood South Atlantic, 606 U.S. ___ (2025)". Justia Law. Retrieved 2025-07-13.
- ^ Howe, Amy (2025-04-02). "Supreme Court hears dispute over South Carolina's bid to defund Planned Parenthood". SCOTUSblog. Retrieved 2025-07-13.
- ^ "Supreme Court rules for South Carolina in its bid to defund Planned Parenthood". NBC News. 2025-06-26. Retrieved 2025-06-26.
- ^ Weixel, Nathaniel (2025-06-26). "Supreme Court rules to allow Medicaid funding cuts for Planned Parenthood". The Hill. Retrieved 2025-06-26.
- ^ "Supreme Court Backs State Bid to Defund Planned Parenthood (2)". Bloomberg News. 2025-06-26. Archived from the original on 2025-07-04. Retrieved 2025-07-13.
External links
Text of Medina v. Planned Parenthood South Atlantic, 606 U.S. __ (2025) is available from: Justia Oyez (oral argument audio)