Medina v. Planned Parenthood South Atlantic
Issues
Does the Medicaid Act’s any-qualified-provider provision give Medicaid beneficiaries a private right to choose their provider?
This case asks the Court to determine when an individual, private right is enforceable under 42 U.S.C. § 1983. South Carolina’s executive order deems abortion clinics enrolled in the Medicaid program as unqualified to provide family planning services. Planned Parenthood South Atlantic and its patient, Julie Edwards, contend that the executive order violates Ms. Edwards’s right to choose a qualified provider under 42 U.S.C. § 1396a(a)(23), the any-qualified-provider provision. South Carolina counters that the any-qualified-provider fails to create a private right of action enforceable through § 1983 because Congress did not use unambiguously clear rights-creating language. The outcome of this case has heavy implications for Medicaid beneficiaries and providers, the implementation of state and federal healthcare policy goals, and the litigation of private rights.
Questions as Framed for the Court by the Parties
Whether the Medicaid Act’s any-qualified-provider provision unambiguously confers a private right upon a Medicaid beneficiary to choose a specific provider.
The Medicaid Act provides medical assistance to certain individuals and families who cannot cover the cost of necessary medical services due to insufficient income and resources. Planned Parenthood South Atlantic v. Medina, 95 F.4th 152 at 156 (4th Cir.
Additional Resources
- Perrin Moore, Gov. McMaster 'confident' Supreme Court will back plan to cut Planned Parenthood funding, ABC 4 News (Dec. 18, 2024).
- Ian Millhiser, The Supreme Court’s new abortion case should be an easy win for Planned Parenthood, Vox (Dec. 19, 2024).
- Harry Painter, U.S. Supreme Court to Decide Fate of Planned Parenthood Medicaid Funding, The Heartland Institute (Feb. 11, 2025).