Advocate Christ Medical Center v. Kennedy

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Advocate Christ Medical Center v. Kennedy | |
Term: 2024 | |
Important Dates | |
Argued: November 5, 2024 Decided: April 29, 2025 | |
Outcome | |
affirmed | |
Vote | |
7-2 | |
Majority | |
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett | |
Dissenting | |
Ketanji Brown Jackson • Sonia Sotomayor |
- This article is about the court case previously known as Advocate Christ Medical Center v. Becerra. It became Advocate Christ Medical Center v. Kennedy following Robert F. Kennedy Jr.'s appointment as secretary of the U.S. Department of Health and Human Services.
Advocate Christ Medical Center v. Kennedy is a case that was decided by the Supreme Court of the United States on April 29, 2025, during the court's October 2024-2025 term. The case was argued before the Supreme Court of the United States on November 5, 2024.
The case came on a writ of certiorari to the United States Court of Appeals for the District of Columbia Circuit. To review the lower court's opinion, click here.
Background
Case summary
The following are the parties to this case:[2]
- Petitioner: Advocate Christ Medical Center, et al.
- Legal counsel: Hyland Hunt (Deutsch Hunt, PLLC)
- Respondent: Robert F. Kennedy Jr., Secretary of Health and Human Services
- Legal counsel: D. John Sauer (United States Solicitor General)[3]
The following summary of the case was published by SCOTUSblog:[4]
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[In Advocate Christ Medical Center v. Becerra, the Justices] have been asked to decide how to calculate payments by Medicare to provide additional compensation to hospitals that care for large numbers of Medicare beneficiaries and uninsured patients – and, in particular, how to determine, for purposes for that calculation, whether patients are “entitled to” cash benefits through the Supplemental Security Income program.[5] |
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To learn more about this case, see the following:
Timeline
The following timeline details key events in this case:
- April 29, 2025: The U.S. Supreme Court affirmed the judgment of the United States Court of Appeals for the District of Columbia Circuit.
- November 5, 2024: The U.S. Supreme Court heard oral argument.
- June 10, 2024: The U.S. Supreme Court agreed to hear the case.
- December 29, 2023: Advocate Christ Medical Center appealed to the U.S. Supreme Court.
- September 1, 2023: The United States Court of Appeals for the District of Columbia Circuit affirmed the United States District Court for the District of Columbia's grant of summary judgment to the Secretary of Health and Human Services.[6]
Questions presented
The petitioner presented the following questions to the court:[1]
Questions presented:
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Oral argument
Audio
Audio of oral argument:[7]
Transcript
Transcript of oral argument:[8]
Outcome
In a 7-2 opinion, the court affirmed the judgment of the United States Court of Appeals for the District of Columbia Circuit, holding that when calculating the Medicare fraction, an individual is “entitled to supplementary security income benefits” for the Medicare fraction when they are eligible to receive an supplementary security income benefits cash payment during the month of their hospitalization. Justice Amy Coney Barrett delivered the opinion of the court.[9]
Opinion
In the court's majority opinion, Justice Amy Coney Barrett wrote:[9]
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Just as subchapter XVI makes clear that SSI benefits are cash benefits, it also establishes that eligibility for such benefits is determined on a monthly basis. Section 1382(c)(1) provides that ‘[a]n individual’s eligibility for a benefit under this subchapter for a month shall be determined’ based on the individual’s ‘income, resources, and other relevant characteristics in such month.’ The statute’s reference to termination of benefits also refers back to months of ineligibility: An individual must reapply for the program after she has been ‘ineligible for benefits . . . for a period of 12 consecutive months.’ §1383(j)(1)(B). Other examples similarly confirm that eligibility is a month-tomonth inquiry. See, e.g., §1382(e)(1)(A) (providing that ‘no person shall be an eligible individual . . . with respect to any month if throughout such month he is an inmate of a public institution’); §1382(e)(1)(D) (providing that ‘[a] person may be an eligible individual . . . with respect to any month throughout which he is a resident of a public emergency shelter for the homeless’); §§1382(e)(4)(A)(i)–(ii) (providing that ‘[n]o person shall be considered an eligible individual . . . with respect to any month if during such month the person is . . . fleeing to avoid prosecution’ or violating ‘a condition of probation or parole’). A note for the sake of completeness: While subchapter XVI speaks primarily in terms of eligibility for SSI benefits, the Medicare fraction focuses on whether an individual is entitled to such benefits. Nothing turns on this difference. In Empire Health, we treated the word ‘entitled’ in the Medicare statute (including the Medicare fraction) as synonymous with ‘qualifying’ for or ‘being eligible . . . for benefits.’ 597 U. S., at 435. See also Webster’s Third New International Dictionary 758 (1986) (defining ‘entitle’ as ‘to give a right or legal title to’ or to ‘qualify (one) for something’); id., at 736 (defining ‘eligible’ as ‘fitted or qualified to be chosen or used’ or ‘entitled to something’). This case also involves the Medicare fraction, so we follow the same course. See Brown v. Gardner, 513 U. S. 115, 118 (1994) (noting that the presumption of consistent usage is ‘surely at its most vigorous when a term is repeated within a given sentence’). We therefore conclude that an individual is ‘entitled to [SSI] benefits . . . under subchapter XVI’ when she is eligible to receive an SSI cash payment. And because eligibility is determined on a monthly basis, an individual is considered ‘entitled to [SSI] benefits’ for purposes of the Medicare fraction only if she is eligible for such benefits during the month of her hospitalization. [5] |
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—Justice Amy Coney Barrett |
Dissenting opinion
Justice Ketanji Brown Jackson filed a dissenting opinion, joined by Justice Sonia Sotomayor.
In her dissent, Justice Jackson wrote:[9]
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The decision the majority has made in this case will deprive hospitals serving the neediest among us of critical federal funds that Congress plainly attempted to provide. Hospitals that have a disproportionate share of low-income patients are struggling. Indeed, it is undisputed that systemically undercounting low-income patients for the purposes of the disproportionate-share formula might cause many such hospitals to close their doors entirely, such that patients from our Nation’s poorest communities may not be served at all. Brief for American Hospital Association et al. as Amici Curiae 27–28; Tr. of Oral Arg. 36–38. This outcome is not compelled by the text of the Medicare statute or the circumstances that surround it. Rather, it is, unfortunately, directly attributable to the majority’s incurious and context-free method of statutory analysis. Congress’s reference to the SSI program in the Medicare formula has confused the majority into thinking that Congress meant for hospitals serving low-income patients to be reimbursed at lower rates than if their patient population was fully taken into account. So it will now be up to Congress to restate its intention that low-income people have access to quality medical care and that hospitals be compensated accordingly. I suspect that such a legislative fix would not be too difficult to craft. But Congress would not need to go that extra mile if this Court’s interpretive practices would just take care to evaluate the text of a statute alongside any indisputable legislative objectives. Here, we should have easily concluded that, for purposes of the disproportionate-share formula used to reimburse hospitals, patients are “entitled to” SSI benefits when they are eligible for and enrolled in the SSI program, as Congress undoubtedly intended. [5] |
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—Justice Ketanji Brown Jackson |
Text of the opinion
Read the full opinion here.
October term 2024-2025
The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[10]
See also
External links
- Search Google News for this topic
- U.S. Supreme Court docket file - Advocate Christ Medical Center v. Kennedy (petitions, motions, briefs, opinions, and attorneys)
- SCOTUSblog case file for Advocate Christ Medical Center v. Kennedy
Footnotes
- ↑ 1.0 1.1 U.S. Supreme Court, "23-715 ADVOCATE CHRIST MEDICAL V. BECERRA," June 10, 2024
- ↑ Supreme Court of the United States, "No. 23-715," accessed August 19, 2024
- ↑ Note: When this case was argued, counsel was given by former United States Solicitor General Elizabeth Prelogar.
- ↑ SCOTUSblog, "Justices to review Meta investors’ data-harvesting suit and Medicare payments calculation," June 10, 2024
- ↑ 5.0 5.1 5.2 5.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ United States Court of Appeals for the District of Columbia Circuit, Advocate Christ Med. Ctr. v. Becerra, decided September 1, 2023
- ↑ Supreme Court of the United States, "Oral Argument - Audio," argued November 5, 2024
- ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued November 5, 2024
- ↑ 9.0 9.1 9.2 U.S. Supreme Court, Advocate Christ Medical Center v. Kennedy, decided April 29, 2025
- ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022