Term: 2011
Docket: 09-958
Toby Douglas, Director, California Department Of Health Care Services, Petitioner v. Independent Living Center Of Southern California, Inc., Et Al.
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09-958 DOUGLAS V. INDEPENDENT LIVING CENTER OF SOUTHERN CALIFORNIA DECISION BELOW: 572 F.3d 644 LIMITED TO QUESTION 1 PRESENTED BY THE PETITIONS. CONSOLIDATED WITH 09-1158 AND 10-283 FOR ONE HOUR ORAL ARGUMENT. THE PARTIES AND THE SOLICITOR GENERAL ARE DIRECTED TO FILE SUPPLEMENTAL BRIEFS ADDRESSING THE FOLLOWING QUESTION: “WHAT SHOULD BE THE EFFECT, IF ANY, OF THE DEVELOPMENTS DISCUSSED IN THE LETTER SUBMITTED BY THE SOLICITOR GENERAL ON OCTOBER 28, 2011, ON THE PROPER DISPOSITION OF THIS CASE?” CERT. GRANTED 1/18/2011 QUESTION PRESENTED: Under 42 U.S.C. § 1396a(a)(30)(A) of the Medicaid Act, a state that accepts federal Medicaid funds must adopt a state plan containing methods and procedures to “safeguard against unnecessary utilization of .. . [Medicaid] services and . . . assure that payments are consistent with efficiency, economy, and quality of care and are sufficient to enlist enough providers so that care and services are available . . . at least to the extent that such care and services are available to the general population." The Ninth Circuit, along with virtually all of the circuits to have considered the issue since this Court's decision in Gonzaga University v. Doe, 536 U.S. 273 (2002), concluded that this provision does not confer any "rights" on Medicaid providers or recipients that are enforceable under 42 U.S.C. § 1983, and respondents do not contend otherwise. Nonetheless, in the present case, the Ninth Circuit held that § 1396a(a)(30)(A) preempted a state law reducing Medicaid reimbursement payments because the State failed to produce evidence that it had complied with requirements that do not appear in the text of the statute, and because the reductions were motivated by budgetary considerations. The questions presented are: 1. Whether Medicaid recipients and providers may maintain a cause of action under the Supremacy Clause to enforce § 1396a(a)(30)(A) by asserting that the provision preempts a state law reducing reimbursement rates? 2. Whether a state law reducing Medicaid reimbursement rates may be held preempted by § 1396a(a)(30)(A) based on requirements that do not appear in the text of the statute? LOWER COURT CASE NUMBER: 08-56422, 08-56554
In the case of Toby Douglas, Director, California Department of Health Care Services v. Independent Living Center of Southern California Inc., et al., 2011, the U.S. Supreme Court was asked to determine whether Medicaid providers and beneficiaries could sue a state for not complying with federal Medicaid laws. The dispute arose when California cut its Medicaid reimbursement rates by 10%, which plaintiffs argued violated federal law requiring states to ensure payments are sufficient to enlist enough providers so that care is available under Medicaid at least to the extent it is available to the general population in an area. The court ruled in favor of Independent Living Center (ILC), affirming that private parties can bring suits against states under Supremacy Clause challenges even if Congress has not explicitly created such a right within the statute itself.
In the dissenting opinion for Toby Douglas v. Independent Living Center of Southern California, Inc., Justice Roberts, joined by Justices Scalia, Thomas and Alito argued that Medicaid providers and beneficiaries should not have a cause of action under the Supremacy Clause to challenge state laws they believe are inconsistent with federal Medicaid law. They contended that it is up to Congress or administrative agencies like Health and Human Services (HHS) to decide whether a state's actions comply with federal law. The dissenters believed that allowing private parties to sue states over alleged non-compliance would disrupt the balance between states and the federal government in administering joint programs like Medicaid. They also expressed concern about courts being flooded with lawsuits from individuals claiming some state rule does not align perfectly with their interpretation of federal regulations.
