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Medina v. Planned Parenthood South Atlantic

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Supreme Court of the United States
Medina v. Planned Parenthood South Atlantic
Term: 2024
Important Dates
Argued: April 2, 2025
Decided: June 26, 2025
Outcome
reversed and remanded
Vote
6-3
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett •
Concurring
Clarence Thomas
Dissenting
Ketanji Brown Jackson • Sonia Sotomayor • Elena Kagan
This article is about the court case previously known as Kerr v. Planned Parenthood South Atlantic. It became Medina v. Planned Parenthood South Atlantic following Eunice Medina's appointment as acting director of the South Carolina Department of Health and Human Services.

Medina v. Planned Parenthood South Atlantic is a case that was decided by the Supreme Court of the United States on June 26, 2025, during the court's October 2024-2025 term. The case was argued before the Supreme Court of the United States on April 2, 2025.

In a 6-3 opinion, the court reversed and remanded the judgment of the United States Court of Appeals for the Fourth Circuit. The court held that 42 U. S. C. §1983 allows private plaintiffs to sue for violations of federal spending-power statutes only in atypical situations where the provision clearly and unambiguously gives an individual the rights to do so. SCOTUS held that Section 1396a(a)(23)(A) is not that statute. Justice Neil Gorsuch delivered the opinion of the court.[1]

HIGHLIGHTS
  • The issue: The case concerned whether Medicaid's provision allowing patients to choose "any qualified provider," unambiguously provides the ability of the patient to choose a specific qualified provider. Click here to learn more about the case's background.
  • The questions presented: "Whether the Medicaid Act's any-qualified-provider provision unambiguously confers a private right upon a Medicaid beneficiary to choose a specific provider."[2]
  • The outcome: The court reversed and remanded the judgment of the United States Court of Appeals for the Fourth Circuit.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the Fourth Circuit. To review the lower court's opinion, click here.

    Background

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: Eunice Medina, Interim Director, South Carolina Department of Health and Human Services[4]
      • Legal counsel: John J. Bursch (Alliance Defending Freedom)
    • Respondent: Planned Parenthood South Atlantic, et al.
      • Legal counsel: Nicole A. Saharsky (Mayer Brown LLP)

    The following summary of the case was published by Oyez

    “ Medicaid, established in 1965, is a cooperative federal-state program that provides medical assistance to needy individuals. The program offers federal funding to states that agree to comply with certain conditions, including the “free-choice-of-provider” provision added in 1967, which ensures Medicaid beneficiaries can obtain medical assistance from any qualified provider. States must submit their medical assistance plans to the Secretary of Health and Human Services for approval, and the Secretary can withhold funds if states fail to comply with federal requirements.

    In South Carolina, Planned Parenthood South Atlantic operates two health centers providing various medical services, including contraception, cancer screenings, and STI treatment. Julie Edwards, a Medicaid beneficiary, received care at Planned Parenthood and planned to continue her gynecological care there. However, in July 2018, South Carolina’s Governor issued an executive order directing the Department of Health and Human Services to terminate abortion clinics from the Medicaid program. As a result, DHHS informed Planned Parenthood that it was no longer qualified to provide services to Medicaid beneficiaries and terminated its enrollment agreements immediately. Planned Parenthood and Edwards then sued the Director of DHHS in federal court, seeking to block enforcement of the executive order.

    The district court initially granted a preliminary injunction blocking South Carolina from terminating Planned Parenthood’s Medicaid enrollment, and after multiple appeals to the United States Court of Appeals for the Fourth Circuit and one previous remand from the United States Supreme Court, the Fourth Circuit again held that Medicaid beneficiaries can sue to enforce their right to choose their provider.[5]

    		”

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:

    • June 26, 2025:The U.S. Supreme Court reversed and remanded the judgment of the United States Court of Appeals for the Fourth Circuit.[1]
    • April 2, 2025: The U.S. Supreme Court heard oral argument.
    • December 18, 2024: The U.S. Supreme Court agreed to hear the case. When the case was originally accepted by the U.S. Supreme Court, the case name was Kerr v. Planned Parenthood South Atlantic
    • June 3, 2024: Robert M. Kerr, Director, South Carolina Department of Health and Human Services appealed to the U.S. Supreme Court.
    • March 5, 2024: The United States Court of Appeals for the Fourth Circuit affirmed the lower court's decision.

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether the Medicaid Act's any-qualified-provider provision unambiguously confers a private right upon a Medicaid beneficiary to choose a specific provider.[5] ”

    Oral argument

    Audio

    Audio of oral argument:[6]



    Transcript

    Transcript of oral argument:[7]

    Outcome

    In a 6-3 opinion, the court reversed and remanded the judgment of the United States Court of Appeals for the Fourth Circuit. The court held that 42 U. S. C. §1983 allows private plaintiffs to sue for violations of federal spending-power statutes only in atypical situations where the provision clearly and unambiguously gives an individual the rights to do so. SCOTUS held that Section 1396a(a)(23)(A) is not that statute. Justice Neil Gorsuch delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Neil Gorsuch wrote:[1]

    “

    Section 1396a(a)(23)(A) lacks the required clear rights-creating language. Since Pennhurst, only three sets of spending-power statutes have been found to confer §1983 rights: those in Wright, Wilder, and Talevski. Given this Court’s repudiation of Wright and Wilder’s reasoning, Talevski provides the only reliable measure.

    Talevski addressed Federal Nursing Home Reform Act provisions requiring facilities to ‘protect and promote’ residents’ ‘right to be free from’ restraints and provisions titled ‘[t]ransfer and discharge rights’ in a subsection called ‘[r]equirements relating to residents’ rights.’ §1396r(c) (emphasis added).

    The any-qualified-provider provision looks nothing like these. Section 1396a(a)(23)(A) states that Medicaid plans must ‘provide that . . . any individual eligible for medical assistance . . . may obtain such assistance from any . . . qualified’ provider. This language addresses state duties and may benefit providers and patients, but lacks FNHRA’s clear ‘rights-creating language,’ Talevski, 599 U. S., at 186 (internal quotation marks omitted). Congress knows how to create clear rights, as FNHRA shows by giving nursing-home residents ‘the right to choose a personal attending physician.’ §1396r(c)(1)(A)(i) (emphasis added). But that is not the law here. [5]

    		”
    —Justice Neil Gorsuch

    Concurring opinion

    Justice Clarence Thomas filed a concurring opinion.

    In his concurring opinion, Justice Thomas wrote:[1]

    “

    Individual plaintiffs may invoke Rev. Stat. §1979, 42 U. S. C. §1983, to sue state or local officials who have deprived them of ‘any rights, privileges, or immunities secured by the Constitution and laws.’ In other words, §1983 provides a mechanism for plaintiffs to enforce constitutional or statutory provisions that confer personally held federal rights. The Court correctly holds today that §1396a(a)(23)(A) of the Medicaid Act is not such a provision. Its decision properly limits plaintiffs’ ability to bring §1983 suits premised on conditional spending legislation, and I join in full. I write separately because it behooves us to reexamine more broadly this Court’s §1983 jurisprudence, which bears little resemblance to the statute as originally understood. In appropriate cases, we should reassess §1983’s bounds, including its application in the spending context and our understanding of the ‘rights’ enforceable under §1983.[5]

    		”
    —Justice Clarence Thomas

    Dissenting opinion

    Justice Ketanji Brown Jackson filed a dissenting opinion, joined by Justices Sonia Sotomayor and Elena Kagan.

    In her dissent, Justice Brown Jackson wrote:[1]

    “

    Congress enacted the Medicaid Act’s free-choice-of-provider provision to ensure that Medicaid recipients have the right to choose their own doctors. The Court’s decision to foreclose Medicaid recipients from using §1983 to enforce that provision thwarts Congress’s will twice over: once, in dulling the tool Congress created for enforcing all federal rights, and again in vitiating one of those rights altogether. The Court’s decision today is not the first to so weaken the landmark civil rights protections that Congress enacted during the Reconstruction Era. See, e.g., Civil Rights Cases, 109 U. S. 3 (1883); United States v. Cruikshank, 92 U. S. 542 (1876); Blyew v. United States, 13 Wall. 581 (1872). That means we do have a sense of what comes next: as with those past rulings, today’s decision is likely to result in tangible harm to real people. At a minimum, it will deprive Medicaid recipients in South Carolina of their only meaningful way of enforcing a right that Congress has expressly granted to them. And, more concretely, it will strip those South Carolinians—and countless other Medicaid recipients around the country—of a deeply personal freedom: the ‘ability to decide who treats us at our most vulnerable.’ Kerr, 95 F. 4th, at 169. The Court today disregards Congress’s express desire to prevent that very outcome.[5]

    		”
    —Justice Ketanji Brown Jackson

    Text of the opinion

    Read the full opinion here.

    October term 2024-2025

    See also: Supreme Court cases, 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.[8]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 Supreme Court of the United States, "Medina v. Planned Parenthood South Atlantic," June 26, 2025
    2. ↑ 2.0 2.1 Supreme Court of the United States, "23-1275 KERR V. PLANNED PARENTHOOD SOUTH ATLANTIC QP", December 18, 2024
    3. ↑ Supreme Court of the United States, "No. 23-1275," accessed February 6, 2025
    4. ↑ Note: When this case's writ of certiorari was accepted, the petitioner was former South Carolina Department of Health and Human Services Robert Kerr. As such, this case's name was Kerr v. Planned Parenthood South Atlantic. Following Kerr's retirement, the case's name was updated.
    5. ↑ 5.0 5.1 5.2 5.3 5.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued April 2, 2025
    7. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued April 2, 2025
    8. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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