Jun 26, 2025

Supreme Court in a 6-3 rules in favor of South Carolina in Planned Parenthood lawsuit

 


The Supreme Court in a 6-3 ruled in favor of South Carolina saying Planned Parenthood cannot sue the state for termination of Medicaid funding for providing abortion services.

In Medina v. Planned Parenthood South Atlantic, the majority did not agree with Planned Parenthood's and individual plaintiff's  claim that that individual Medicaid patients can sue or have right to pick a medical provider. 

The coverage on this issue depends on the "mainstream media" you read and the bias of that msm outlet.

I added California Attorney General Rob Bonta's statement issued at 4:50 p.m. today. "Patients Should Choose Trusted Medical Providers, Not Politicians."

From page 1 and 2:

Congress created Medicaid in 1965 to subsidize state healthcare for families and individuals “whose income and resources are insufficient to meet the costs of necessary medical services.”  §1396–1. Medicaid offers States “a bargain”: federal funds in exchange for compliance with congressionally imposed conditions.  To participate in Medicaid, States must submit a “plan for medical assistance” satisfying over 80 conditions in §1396a(a). If a State fails “to comply substantially” with any condition, the Secretary of Health and Human Services may withhold federal funding.  §1396c.  This case involves the any-qualified-provider provision in §1396a(a)(23)(A), which requires States to ensure that “any individual eligible for medical assistance . . . may obtain” it “from any [provider] qualified to perform the service . . . who undertakes to provide” it. The provision does not define “qualified,” leaving that to States’ traditional authority over health and safety matters.  The question is whether individual Medicaid beneficiaries may sue state officials under 42 U. S. C. §1983 for failing to comply with the any-qualified-provider provision. Planned Parenthood South Atlantic operates two clinics in South Carolina, offering a wide range of services to Medicaid and non-Medicaid patients.  It also performs abortions.  Citing state law prohibiting public funds for abortion, South Carolina in July 2018 determined that Planned Parenthood could no longer participate in the State’s Medicaid program. At the same time, the State took steps that, it said would help ensure that other providers would continue offering necessary medical care and family planning services. 

Planned Parenthood and patient Julie Edwards sued, claiming the exclusion of Planned Parenthood violated the any-qualified-provider provision.  Edwards alleged she preferred Planned Parenthood for gynecological care but needed Medicaid coverage. They brought a §1983 class action “to vindicate rights secured by the federal Medicaid statutes.” Section 1983 allows private parties to sue state actors who violate their “rights” under the federal “Constitution and laws.”  But federal statutes do not automatically confer §1983-enforceable “rights.”  This is especially true of spending-power statutes like Medicaid, where “the typical remedy” for violations is federal funding termination, not private suits. Gonzaga Univ. v. Doe, 536 U. S. 273, 280. 

California Attorney General Rob Bonta's statement:

California Attorney General Rob Bonta today issued a statement following the U.S. Supreme Court’s decision in Planned Parenthood South Atlantic v. Medina denying Medicaid recipients' individual right to receive care from the qualified providers of their choice, including Planned Parenthood. In a 6-3 opinion, the U.S. Supreme Court ruled that Medicaid beneficiaries do not have a private right of action to obtain assistance from any institution that is “qualified to perform the service or services required” under the Medicaid Act’s free-choice-of-provider provision  because the any-qualified-provider provision, passed by Congress, does not clearly and unambiguously confer individual rights enforceable under §1983. The case began when the state of South Carolina unlawfully terminated Planned Parenthood South Atlantic’s (Planned Parenthood) participation in Medicaid only because the organization performed abortions outside of the Medicaid program. As a result of the termination, Planned Parenthood immediately had to begin turning away Medicaid patients.

“Congress expressly granted patients the right to choose a qualified doctor or provider they trust while seeking medical care. Today’s decision got it wrong: It strips choice out of the hands of patients, and allows politicians to block patients from making their own decisions about their own healthcare,” said Attorney General Bonta. “The impacts of this decision are likely to harm real people, especially low-income residents of South Carolina and other Medicaid beneficiaries who turn to Planned Parenthood for critical services, including physical exams, pregnancy testing and counseling, and screening for conditions such as diabetes, depression, and high blood pressure. In California, we will continue to defend patients’ access to choose providers they trust, including qualified providers like Planned Parenthood.”  

As part of a coalition of 17 attorneys general, Attorney General Bonta previously filed an amicus brief with the U.S. Supreme Court in support of Medicaid recipients' individual right to receive care from the qualified providers of their choice, including Planned Parenthood.

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