In the 1980 case Florida Department of Health and Rehabilitative Services et al. v. Florida Nursing Home Association et al., the U.S Supreme Court addressed a dispute between the state's health department and nursing homes over Medicaid reimbursement rates. The nursing home association argued that changes to these rates, which were lower than what they believed was necessary for providing adequate care, violated federal law requiring "reasonable and adequate" compensation for such services. They sought an injunction against enforcement of the new rate structure until it could be reviewed in court. However, both district courts ruled in favor of the health department stating that there was no violation as long as procedures were followed correctly when setting those rates. The Supreme Court affirmed this decision on appeal, ruling that states have considerable discretion in determining Medicaid payment levels under federal law so long as their methodologies are reasonable and consistent with efficiency, economy, quality of care and access to services - even if providers disagree with them or find them inadequate.

In the dissenting opinion for Florida Department of Health and Rehabilitative Services v. Florida Nursing Home Association, Justice Brennan argued that the Eleventh Amendment should not bar a federal court from ordering state officials to conform their conduct to requirements of federal law. He disagreed with the majority's interpretation of Edelman v. Jordan, asserting it was too broad and would potentially immunize states from important aspects of federal regulation. Brennan contended that when a state voluntarily participates in a federally funded program like Medicaid, it consents to comply with all conditions attached by Congress - including potential enforcement actions in federal courts if they fail to meet those conditions. Therefore, he believed that lawsuits seeking compliance with such conditions do not violate sovereign immunity principles embodied in the Eleventh Amendment as interpreted by previous case law.