Term: 2003
Docket: 02-628
Linda Frew, On Behalf Of Her Daughter, Carla Frew, Et Al. v. Albert Hawkins, Commissioner, Texas Health And Human Services Commission, Et Al.
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02-628 FREW v. HAWKINS Ruling below: CA 5, 300 F.3d 530. QUESTIONS PRESENTED This case involves the Early and Periodic Screening Diagnosis and Treatment (EPSDT) component of the Medicaid Act. 42 U.S.C. §§ 1396a(a)(43); 1396d(r). Another case pending before this Court also involves EPSDT. Haveman v. Westside Mothers, No.02-277 . If the Court grants a writ of certiorari in that case to address questions related to this case, the Petitioner-children ask the Court to suspend this case pending resolution of the other. I. Do State officials waive Eleventh Amendment immunity by urging the district court to adopt a consent decree when the decree is based on federal law and specifically provides for the district court's ongoing supervision of the officials' decree compliance? 2. Does the Eleventh Amendment bar a district court from enforcing a consent decree entered into by State officials unless the plaintiffs show that the "decree violation is also a violation of a federal right" remediable under § 1983 ? 3. Does State officials' failure to provide services required by the Medicaid Act's EPSDT provisions violate rights that Medicaid recipients may enforce pursuant to 42 U.S.C. § 1983? See 42 U.S.C. §§ 1396a(a)(43); 1396d(r). CERT. GRANTED: 3/10/03 Limited to questions 1 and 2 presented by the petition.
In the 2003 case of Frew v. Hawkins, Linda Frew and other plaintiffs sued Albert Hawkins, Commissioner of Texas Health and Human Services Commission on behalf of their children who were Medicaid beneficiaries. The lawsuit was based on allegations that Texas failed to fulfill its obligations under a federal Medicaid law requiring states to provide certain preventative health services for children (Early Periodic Screening Diagnosis Treatment). The Supreme Court ruled in favor of the plaintiffs with a unanimous decision stating that private individuals could sue states over failure to comply with federal Medicaid laws. This ruling reinforced the supremacy clause which asserts that state governments must adhere to federal mandates when they accept federal funding. It also emphasized the importance of ensuring access to healthcare for low-income families through programs like Medicaid.
In the dissenting opinion for Frew v. Hawkins, Justice Antonin Scalia argued that the court had overstepped its bounds by enforcing a federal law that was not explicitly stated in the Constitution. He believed that this case should have been decided at the state level and criticized his colleagues for creating an "unprecedented" interpretation of federal law to justify their decision. Scalia contended that Medicaid is a cooperative program between states and the federal government, but it does not give individuals a right to sue if they believe their state is not complying with federal guidelines. He also expressed concern about potential negative consequences of this ruling, such as increased litigation against states and further erosion of state sovereignty.
