Planned Parenthood Lost Supreme Court Case Based on South Carolina Ban for Medicaid Abortion Providers

Publication Date: June 27, 2025

Overview

In Medina v. Planned Parenthood South Atlantic, the Supreme Court held on June 26, 2025, that the Medicaid Act’s requirement that states allow beneficiaries to obtain services “from any … qualified provider” (§ 1396a(a)(23)(A)) does not itself create an individual right enforceable under 42 U.S.C. § 1983.

Writing for the majority, Justice Gorsuch emphasized that spending-power statutes like Medicaid are akin to contracts between Congress and the states, and that private enforcement requires “clear and unambiguous” rights-creating language—absent here. The decision reverses the Fourth Circuit’s ruling that had blocked South Carolina’s exclusion of Planned Parenthood from its Medicaid program, and it remands for further proceedings consistent with this stringent enforceability test.

Facts

Medicaid Authorization (1965): Congress created Medicaid to subsidize state healthcare for low-income individuals and families, requiring states to submit plans meeting over 80 conditions. (§ 1396–1; § 1396a(a))
Any-Qualified-Provider Provision: Section 1396a(a)(23)(A) directs that “any individual eligible for medical assistance … may obtain such assistance from any … qualified provider … who undertakes to provide [it].” The term “qualified” is undefined and left to state discretion.
South Carolina Action (July 2018): Citing a state law prohibiting public funding of abortion, the South Carolina Department of Health excluded Planned Parenthood South Atlantic from its Medicaid provider network, while affirming that other providers would deliver covered services.
District and Appellate Rulings: Planned Parenthood and patient Julie Edwards sued under § 1983, and both the district court and Fourth Circuit held the exclusion violated the any-qualified-provider provision and enjoined the state action.
Supreme Court Review: The Court granted certiorari to decide whether § 1396a(a)(23)(A) “clearly and unambiguously” confers individual rights enforceable through § 1983, applying precedent from Gonzaga Univ. v. Doe and Health & Hospital Corp. v. Talevski.

Perspectives

Majority (Justice Gorsuch): The Medicaid any-qualified-provider clause lacks “clear rights-creating language,” so it does not furnish a § 1983 cause of action. Spending-power statutes are “much in the nature of a contract,” with enforcement via funding termination, not private suit.
Dissent (Justice Jackson, joined by Sotomayor & Kagan): Argued that the majority’s formalistic approach undermines beneficiaries’ real-world ability to choose providers, contending Congress intended private enforcement to ensure meaningful access.
Planned Parenthood South Atlantic: Contended that depriving Medicaid patients of access to its clinics violated their statutory right to choose any qualified provider and frustrated the availability of reproductive and family-planning services.
Julie Edwards (Medicaid Patient): As an enrolled beneficiary who relied on Planned Parenthood for gynecological care, she asserted that the exclusion forced her to seek less-familiar or more remote providers, impairing her continuity of care.
State of South Carolina (HHS Director Medina): Maintained compliance by directing beneficiaries to alternative providers and argued that allowing private suits would upend the Medicaid funding scheme and infringe on state authority over health and safety regulation.

Considerations

Separation of Powers: The decision reinforces that policy choices about private enforcement of federal spending programs are for Congress, not the courts.
Medicaid Enforcement Mechanisms: States remain subject to funding-termination for noncompliance, and beneficiaries must rely on administrative remedies rather than § 1983 suits.
State Regulatory Authority: By declining to import private causes of action, states retain broader discretion to define “qualified” providers under public-health and safety standards.
Impact on Beneficiary Access: Without a private right to sue, patients may have limited leverage to challenge provider exclusions that affect their care choices.
Future Congressional Action: Congress could amend the Medicaid Act to include explicit “rights-creating” terms or a private-enforcement clause if it wishes to provide beneficiaries a direct cause of action.
Judicial Precedent Boundaries: This ruling underscores the “demanding” threshold for § 1983 enforceability in spending-power statutes, likely confining private enforcement to “atypical” contexts.