The U.S. Supreme Court case L. Douglas Wilder, Governor of Virginia, et al. v. Virginia Hospital Association in 1989 revolved around the interpretation of a provision in the Medicaid Act that required states to pay hospitals for services rendered to eligible patients "promptly." The state of Virginia had been delaying payments due to budgetary constraints and was sued by the Virginia Hospital Association (VHA). The VHA argued that this delay violated federal law under the Medicaid Act's prompt payment requirement. The court ruled in favor of VHA stating that while Congress did not explicitly define what constituted 'prompt' payment, it intended for states participating in Medicaid to make timely payments as part of their obligation under federal law. Therefore, consistent delays were deemed unacceptable and contrary to statutory requirements.

In the dissenting opinion for L. Douglas Wilder, Governor of Virginia, et al. v. Virginia Hospital Association (1989), Justice Thurgood Marshall argued that the majority's decision was a misinterpretation of federal law and an overreach into state affairs. He contended that Congress had not intended to allow private parties to sue states under the Boren Amendment but rather left it up to Health and Human Services (HHS) Secretary to enforce compliance with its provisions through administrative procedures or by withholding federal funds from noncompliant states. Furthermore, he believed that allowing such suits would undermine cooperative federalism by encouraging litigation instead of negotiation between states and HHS in determining reasonable rates for Medicaid services.