On June 26, 2025, the U.S. Supreme Court held that Medicaid beneficiaries have no recourse under 42 U.S.C. § 1983 (Section 1983) to enforce their right under the Medicaid Act to receive care from any qualified provider of their choice. The decision in Medina v. Planned Parenthood South Atlantic, No. 23-1275, 606 U.S. ___ (2025) resolves a circuit split and has broad implications for private enforcement of federal spending statutes, particularly in the Medicaid context.

Case Background

In July 2018, South Carolina’s governor issued an executive order prohibiting clinics that render abortion services from participating in the state’s Medicaid program, even if they provide other types of covered services in addition to abortions. Planned Parenthood, along with patient Julie Edwards, sued the state, claiming that the exclusion violates the “any-qualified-provider” provision in the Medicaid statute. That provision requires states to ensure that “any individual eligible for medical assistance . . . may obtain” it “from any [provider] qualified to perform the service . . . who undertakes to provide” it. 42 U.S.C. § 1396a(a)(23)(A). The plaintiffs brought a class action under Section 1983, which allows private parties to sue state actors who violate their “rights” under the federal “Constitution and laws.” The state argued that federal statutes, like Medicaid, do not automatically confer enforceable “rights” under Section 1983.Continue Reading Supreme Court Says Beneficiaries Have No Section 1983 Private Right of Action to Enforce Medicaid Provider Choice Provisions