Spending Power

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A series of reforms passed by the California Assembly in 2008 and 2009 reduced the state’s payments made to California Medicaid providers. Respondents Independent Living Center of Southern California, the California Pharmacists Association, and Santa Rosa Memorial Hospital brought suit in the U.S. District Court for the Central District of California, claiming that the payment reductions violated 42 U.S.C. § 1396a(a)(30)(A), which requires that state Medicaid plans comply with federal law or lose federal funding. Petitioner Toby Douglas, the Director of the Department of Health Care Services for the State of California, argues that health care providers cannot sue to enforce § 30(A) because the statute does not grant any enforceable rights, and Congress did not intend for private parties to sue to enforce the statute. Conversely, the health care providers argue that the Supremacy Clause permits private parties to sue if they have suffered an injury from state action, and they assert that Congress did not explicitly disallow private lawsuits in § 30(A). The Supreme Court’s decision will affect the predictability of federal law, the ability of private parties to bring lawsuits to enforce federal law, and the availability of health care to Medicaid beneficiaries.

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This case asks the court to analyze both 42 U.S.C. § 1983 and the Federal Nursing Home Reform Act (“FNHRA”), 42 U.S.C. § 1396r et seq., to decide whether FNHRA, a Spending Clause statute, creates enforceable private rights of action under § 1983. Petitioners Health and Hospital Corporation of Marion County, Indiana (“HHC”) argue that contrary to the Supreme Court’s holding in Wilder v. Virginia Hospital Association, § 1983 does not imply a private right of action for Spending Clause legislation unless the legislation expressly includes a private right of action. HHC further contends that even if Spending Clause legislation can imply a private right of action, there is no private right of action under FNHRA because its language does not grant statutory rights to patients and because it contains an individualized enforcement mechanism which precludes § 1983 enforcement. Respondent Ivanka Talevski counters that the plain text of § 1983 unambiguously creates a private right of action whenever Congress uses Spending Clause legislation to protect a federal right and argues that overturning Wilder would contradict decades of judicial and legislative precedent. Talevski further argues that FNHRA’s language clearly establishes statutory federal rights. This case touches on important questions regarding healthcare administration, the protection of nursing home residents, federalism, and the separation of powers. 

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This case asks the Supreme Court to consider whether a violation of the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) by a government official allows for an individual to seek monetary damages against that official in their individual capacity. Landor contends that RLUIPA should be interpreted identically to the Religious Freedom Restoration Act of 1993 (RFRA), which allows for individual-capacity monetary damages against a government official. Landor also argues that the Spending Clause of the United States Constitution permits RLUIPA to allow for these damages. The Louisiana Department of Corrections and Public Safety argues that RLUIPA is distinct from RFRA precisely because the Spending Clause of the Constitution precludes individual liability of state officials, so RFRA and RLUIPA should not be interpreted identically. This case directly impacts freedom of religion rights in prisons, specifically for religious minorities, and the deterrence of future violations of those rights.

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