606 U.S. 357 (2025) · 2025
Medina v. Planned Parenthood South Atlantic
health careMedicaidreproductive healthcivil rights enforcementprovider choicefederalismLandmark
Summary
Medina v. Planned Parenthood South Atlantic asked whether Medicaid beneficiaries may use § 1983 to enforce the Medicaid Act's any-qualified-provider provision. South Carolina had excluded Planned Parenthood South Atlantic from its Medicaid program, and a patient sued to keep using Planned Parenthood for covered non-abortion care. The Supreme Court held 6-3 that the statute does not clearly and unambiguously create an individual right enforceable through § 1983. The result gives states more room to exclude providers from Medicaid without facing this kind of patient enforcement lawsuit in federal court.
Background & Context
Medicaid is a federal-state program that helps pay for health care for people with low incomes and limited resources. The any-qualified-provider provision requires state Medicaid plans to let eligible patients obtain covered care from qualified providers willing to provide it. South Carolina excluded Planned Parenthood South Atlantic from Medicaid participation because it performs abortions, even though the dispute involved Medicaid coverage for non-abortion services. The legal question focused on private enforcement, not the medical qualification of any specific provider.
The Question Before the Court
Does 42 U.S.C. § 1396a(a)(23)(A), the Medicaid Act's any-qualified-provider provision, clearly and unambiguously create an individual right that Medicaid beneficiaries may enforce against state officials through 42 U.S.C. § 1983?
Petitioner
Eunice Medina, Director, South Carolina Department of Health and Human Services
Party asking the Court to review or reverse
Argued
- The Medicaid Act does not clearly create a private right enforceable through § 1983.
- The any-qualified-provider provision is directed at state plan requirements.
- Provider qualifications are traditionally handled by states.
Respondent
Planned Parenthood South Atlantic, et al.
Party defending the judgment below
Argued
- The statute protects Medicaid patients' choice of qualified providers.
- Section 1983 is a historic civil-rights enforcement tool.
- Without private enforcement, patients may have no realistic remedy.
The Holding
Section 1396a(a)(23)(A) of the Medicaid Act does not clearly and unambiguously confer individual rights enforceable under 42 U.S.C. § 1983. Medicaid beneficiaries therefore cannot use § 1983 to sue state officials for alleged violations of that any-qualified-provider provision.
The Court
How the justices lined up in this decision.
6-3
Vote
Joined decision
6 justicesAC
Amy Barrett
Majority
BK
Brett Kavanaugh
Majority
CT
Clarence Thomas
Majority
JR
John Roberts
Majority
NG
Neil Gorsuch
Majority
SA
Samuel Alito
Majority
Dissented
3 justicesEK
Elena Kagan
Dissent
KB
Ketanji Jackson
Dissent
SS
Sonia Sotomayor
Dissent
What this means for you
The ruling makes it harder for Medicaid patients to challenge provider exclusions in federal court. In states that exclude Planned Parenthood or similar providers, patients may lose access to a familiar provider for contraception, STI testing, cancer screenings, pregnancy testing, and other non-abortion care covered through Medicaid. The decision does not itself ban Planned Parenthood from providing care, and it does not decide whether a state exclusion is good health policy. It narrows one legal tool patients used to enforce Medicaid provider-choice rules.
Key Takeaways
- The Court held that Medicaid's any-qualified-provider provision is not enforceable by private patients through § 1983.
- The majority treated Medicaid as spending-power legislation, where private enforcement requires especially clear rights-creating language.
- The case arose from South Carolina's exclusion of Planned Parenthood South Atlantic from Medicaid reimbursement.
- The decision affects access to non-abortion care because Medicaid funds generally cannot be used for abortions, but Planned Parenthood also provides contraception, STI testing, cancer screenings, pregnancy testing, and other covered services.
- The dissent warned that the ruling leaves Medicaid patients with fewer practical ways to enforce provider-choice protections.
Decision
6-3 majority opinion
- Citation
- 606 U.S. 357 (2025)
- Vote
- 6-3
- Decision type
- Majority opinion
- Argued
- April 2, 2025
- Decided
- June 26, 2025
- Term
- 2024
- Opinion author
- Neil Gorsuch
Justice Gorsuch wrote the Court's opinion, joined by Chief Justice Roberts and Justices Thomas, Alito, Kavanaugh, and Barrett. Justice Thomas filed a concurrence. Justice Jackson dissented, joined by Justices Sotomayor and Kagan.