Opinion Summary: Medina v. Planned Parenthood South Atlantic | Date Decided: 6/26/25 | Case No. 23–1275

Link to Docket: Here.

Background:

More than 30 years ago, this Court first applied what would become known as the "Blessing factors," holding that a Medicaid Act provision created a privately enforceable right to certain reimbursement rates. Wilder v. Va. Hosp. Ass'n, 496 U.S. 498, 509-10 (1990). Later, the Court distilled from Wilder a multi-factor test for deciding whether a "statutory provision gives rise to a federal right" privately enforceable under Section 1983. Blessing v. Freestone, 520 U.S. 329, 340 (1997). Five years later, though, the Court disparaged Blessing's test while clarifying that only "an unambiguously conferred right is enforceable by § 1983." Gonzaga University v. Doe, 536 U.S. 273, 282 (2002). Then, in Health & Hospital Corp. of Marion County v. Talevski, 599 U.S. 166, 180 (2023), the Court doubled down on Gonzaga's "demanding bar."

The Court did not apply Blessing or Wilder in Talevski, but it did not overrule them either. After the Court GVR'd this case in light of Talevski, the Fourth Circuit applied Wilder and Blessing again and reaffirmed its prior opinions, maintaining a 5-2 circuit split over the first question presented and a 3-1 circuit split over the proper reading of O'Bannon v. Town Court Nursing Center, 447 U.S. 773 (1980), which frames the second question.

Questions Presented:

1. Whether the Medicaid Act's any-qualified-provider provision unambiguously confers a private right upon a Medicaid beneficiary to choose a specific provider.

2. What is the scope of a Medicaid beneficiary's alleged right to choose a provider that a state has deemed disqualified?

Holding: Section 1396a(a)(23)(A) does not clearly and unambiguously confer individual rights enforceable under Section 1983.

Result: Reversed and remanded.

Voting Breakdown: 6-3. Justice Gorsuch delivered the opinion of the Court, in which Chief Justice Roberts and Justices Thomas, Alito, Kavanaugh, and Barrett joined. Justice Thomas filed a concurring opinion. Justice Jackson filed a dissenting opinion, in which Justices Sotomayor and Kagan joined.

Link to Opinion: Here.

Oral Advocates:

• For petitioner: John J. Bursch, Washington, D.C.; and Kyle D. Hawkins, Counselor to the Solicitor General, Department of Justice, Washington, D.C. (for United States, as amicus curiae.)
• For respondents: Nicole A. Saharsky, Washington, D.C.

Website Link to Oral Argument: Here.

Apple Podcast Link to Oral Argument: Here.