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Moyle v. United States
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| Moyle v. United States | |
| Term: 2023 | |
| Important Dates | |
| Argued: April 24, 2024 Decided: June 27, 2024 | |
| Outcome | |
| Dismissed | |
| Vote | |
| Per curiam | |
| Majority | |
| Per curiam | |
| Concurring | |
| Chief Justice John Roberts • Sonia Sotomayor • Elena Kagan • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson (in part) | |
| Dissenting | |
| Clarence Thomas • Samuel Alito • Neil Gorsuch (in part) • Ketanji Brown Jackson (in part) | |
Moyle v. United States is a U.S. Supreme Court case dismissed on June 27, 2024, that aimed to challenge the Emergency Medical Treatment and Labor Act (EMTALA)—a federal law that requires hospitals to provide necessary stabilizing treatment to pregnant women in emergencies which, in the Biden administration’s view, includes emergency abortions. Idaho and the state legislature challenged the federal law, arguing in part that it conflicts with the Idaho Defense of Life Act. The Supreme Court dismissed the case as improvidently granted in a per curiam decision.
The case was argued before the Supreme Court of the United States on April 24, 2024, during the court’s October 2023-2024 term. It was consolidated with Idaho v. United States.[1]
The cases came on a writ of certiorari to the United States Court of Appeals for the Ninth Circuit. To review the lower court's opinion, click here.
Why it matters: The case concerned whether the Emergency Medical Treatment and Labor Act (EMTALA) preempts Idaho’s Defense of Life Act and had the potential to impact the interpretation of the EMTALA outlined in guidance issued in 2022 by the Biden administration. The decision allows emergency abortions to continue in Idaho, however, the court did not rule on the merits of the case and instead dismissed the case as improvidently granted.[3]
Timeline
The following timeline details key events in Mike Moyle v. United States:
- June 27, 2024: The U.S. Supreme Court dismissed the case as improvidently granted.
- April 24, 2024: The U.S. Supreme Court heard oral argument.
- January 5, 2024: The U.S. Supreme Court agreed to hear the case.
- November 20, 2023: Mike Moyle submitted an application for a stay to Justice Elena Kagan.
- November 13, 2023: The United States Court of Appeals for the Ninth Circuit declined to issue a stay on the U.S. District Court for the District of Idaho's decision to prevent Idaho from enforcing its Defense of Life Act, to the extent that it conflicted with the Emergency Medical Treatment and Labor Act.
The following timeline details key events in Idaho v. United States:
- June 27, 2024: The U.S. Supreme Court dismissed the case as improvidently granted.
- April 24, 2024: The U.S. Supreme Court heard oral argument.
- January 5, 2024: The U.S. Supreme Court agreed to hear the case.
- November 20, 2023: Idaho appealed to the U.S. Supreme Court.
- November 13, 2023: The United States Court of Appeals for the Ninth Circuit declined to issue a stay on the U.S. District Court for the District of Idaho's decision to prevent Idaho from enforcing its Defense of Life Act, to the extent that it conflicted with the Emergency Medical Treatment and Labor Act.
Background
| Administrative State |
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| Five Pillars of the Administrative State |
| • Judicial deference • Nondelegation • Executive control • Procedural rights • Agency dynamics |
| Click here for more coverage of the administrative state on Ballotpedia |
- See also: Guidance
The Biden administration issued guidance in 2022 following the Supreme Court decision in Dobbs v. Jackson Women’s Health Organization stating that hospitals receiving Medicare funding must provide necessary stabilizing treatment to pregnant women in emergencies under the Emergency Medical Treatment and Labor Act (EMTALA) which, in the Biden administration’s view, includes emergency abortions.
Idaho and the state legislature challenged the decision and argued in part that the EMTALA conflicts with Idaho’s Defense of Life Act, which bans abortions in the state. Judge B. Lynn Winmill issued a ruling in the United States District Court for the District of Idaho prohibiting Idaho from enforcing the state law as it conflicted with the EMTALA. The United States Court of Appeals for the Ninth Circuit denied a request from the state to put the ruling on hold throughout the state’s appeal process.
The United States Supreme Court agreed to hear the case in the October 2023-2024 term. The court also granted a temporary hold on the district court ruling that required emergency rooms in Idaho to provide abortions in emergency situations.[3]
Questions presented
The petitioner presented the following questions to the court:[2]
Questions presented:
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Oral argument
Audio
Audio of oral argument:[5]
Transcript
Transcript of oral argument:[6]
Outcome
The court dismissed the case as improvidently granted in a per curiam decision. Justice Elena Kagan filed a concurring opinion, joined by Justice Sonia Sotomayor and joined in part by Justice Ketanji Brown Jackson. Justice Amy Coney Barrett filed a concurring opinion, joined by Chief Justice John Roberts and Justice Brett Kavanaugh. Justice Ketanji Brown Jackson filed an opinion concurring in part and dissenting in part. Justice Samuel Alito filed a dissenting opinion, joined by Justice Clarence Thomas and joined in part by Justice Neil Gorsuch.[1]
Opinion
Opinion of the court
In a per curiam opinion, the court wrote:[7]
| “ |
The writs of certiorari before judgment are dismissed as improvidently granted, and the stays entered by the Court on January 5, 2024, are vacated.[4] |
” |
Concurring opinions
Justice Elena Kagan filed a concurring opinion, joined by Justice Sonia Sotomayor and joined in part by Justice Ketanji Brown Jackson. She argued that Idaho’s arguments did not justify emergency relief from the Supreme Court and contended that the case should proceed through the lower courts with its preliminary injunction in place:[7]
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I concur in the Court’s decision today to vacate its stay and dismiss the writ of certiorari before judgment as improvidently granted. I do so because Idaho’s arguments about EMTALA do not justify, and have never justified, either emergency relief or our early consideration of this dispute. With this Court’s writ of certiorari dismissed, the lower courts can proceed with this litigation in the regular course. And with this Court’s stay dissolved, the District Court’s preliminary injunction will again take effect. That will prevent Idaho from enforcing its abortion ban when the termination of a pregnancy is needed to prevent serious harms to a woman’s health.[4] |
” |
Justice Amy Coney Barrett filed a concurring opinion, joined by Chief Justice John Roberts and Justice Brett Kavanaugh. She argued that the case should be dismissed because the scope of the cases had shifted since the court granted certiorari:[7]
| “ |
Before the Ninth Circuit had the opportunity to review the District Court’s preliminary injunction, this Court stayed the injunction and granted certiorari before judgment. Both decisions were premised on the belief that Idaho would suffer irreparable harm under the injunction and that these cases were ready for the Court’s immediate determination. Since then, briefing and oral argument have ‘shed more light on this case than in the nature of things was afforded at the time; the Court considered petitioners’ emergency applications. Belcher v. Stengel, 429 U.S. 118, 119 (1976) (per curiam) (dismissed as improvidently granted). I am now convinced that these cases are no longer appropriate for early resolution.[4] |
” |
Concurring in part, dissenting in part
Justice Ketanji Brown Jackson filed an opinion concurring in part and dissenting in part. She concurred with the decision to lift the court’s stay, arguing that it “should not have been entered in the first place.” She dissented, however, from the decision to dismiss the case, arguing that the challenge to EMTALA still needs to be addressed:[7]
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We cannot simply wind back the clock to how things were before the Court injected itself into this matter. Our intervention has already distorted this litigation process. We permitted Idaho’s law to go into effect by staying the District Court’s injunction in the first place, then allowed this matter to sit on our merits docket for five months while we considered the question presented. It is too little, too late for the Court to take a mulligan and just tell the lower courts to carry on as if none of this has happened. As the old adage goes: The Court has made this bed so now it must lie in it—by proceeding to decide the merits of the critical pre-emption issue this case presents.
We have granted certiorari and heard argument. We have had ample opportunity to consider the issues. The parties were well represented on both sides, and dozens of amici have weighed in. What is more, the necessary legal reasoning is straightforward, and the answer to the question presented is—or at least should be—quite clear: Idaho law prohibits what federal law requires, so to that extent, under the Supremacy Clause, Idaho’s law is pre-empted.[4] |
” |
Dissenting opinion
Justice Samuel Alito filed a dissenting opinion, joined by Justice Clarence Thomas and joined in part by Justice Neil Gorsuch. He wrote against the decision to dismiss the case arguing that, in his view, the text of EMTALA does not require emergency abortions:[7]
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This about-face is baffling. Nothing legally relevant has occurred since January 5. And the underlying issue in this case—whether EMTALA requires hospitals to perform abortions in some circumstances—is a straightforward question of statutory interpretation. It is squarely presented by the decision below, and it has been exhaustively briefed and argued. In addition to the parties’ briefs, we received 46 amicus briefs, including briefs submitted by 44 States and the District of Columbia; briefs expressing the views of 379 Members of Congress; and briefs from prominent medical organizations. Altogether, we have more than 1,300 pages of briefing to assist us, and we heard nearly two hours of argument. Everything there is to say about the statutory interpretation question has probably been said many times over. That question is as ripe for decision as it ever will be. Apparently, the Court has simply lost the will to decide the easy but emotional and highly politicized question that the case presents. That is regrettable.[4] |
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Text of the opinion
Read the full opinion here.
October term 2023-2024
The Supreme Court began hearing cases for the term on October 2, 2023. 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
- Search Google News for this topic
- U.S. Supreme Court docket file - Moyle v. United States (petitions, motions, briefs, opinions, and attorneys)
- SCOTUSblog case file for Moyle v. United States
- U.S. Supreme Court docket file - Idaho v. United States (petitions, motions, briefs, opinions, and attorneys)
- SCOTUSblog case file for Idaho v. United States
Footnotes
- ↑ 1.0 1.1 SCOTUSblog, "Moyle v. United States," accessed January 30, 2024
- ↑ 2.0 2.1 U.S. Supreme Court, "23-726 MOYLE V. UNITED STATES, Questions presented'," accessed January 5, 2024
- ↑ 3.0 3.1 SCOTUSblog, "Justices take up abortion case pitting state against federal law," January 5, 2024
- ↑ 4.0 4.1 4.2 4.3 4.4 4.5 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Supreme Court of the United States, "Oral Argument - Audio," argued April 24, 2024
- ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued April 24, 2024
- ↑ 7.0 7.1 7.2 7.3 7.4 Justia, "Moyle v. United States, 603 U.S. _ (2024)," accessed June 27, 2024
- ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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