June 26, 2025
The Supreme Court issued a ruling on Thursday affirming that states have the authority to exclude Planned Parenthood from Medicaid funding. This landmark decision came after a legal challenge involving two Planned Parenthood clinics in South Carolina, which cater to both Medicaid and non-Medicaid patients.
In 2018, South Carolina Governor Henry McMaster implemented an executive order that prohibited the allocation of public funds for abortion services, effectively removing Planned Parenthood from the state’s Medicaid program. The executive order was framed as a measure to ensure that public funds were not used for abortions, with the state asserting that alternative healthcare providers would be available to Medicaid patients.
The legal challenge was initiated by Planned Parenthood and a Medicaid recipient, Julie Edwards. They argued that the state's exclusion of Planned Parenthood from Medicaid funding violated federal law, specifically Section 1396a(a)(23)(A), which they claimed allows Medicaid patients to choose any qualified healthcare provider. This lawsuit was filed under Section 1983, a federal statute that permits individuals to sue state actors for violations of rights protected by the Constitution or federal statutes.
The central issue before the court was whether Medicaid recipients could sue state officials under Section 1983 for not adhering to the so-called "any-qualified-provider" provision. Justice Neil Gorsuch, who articulated the court's opinion, focused on whether the language of Section 1396a(a)(23)(A) clearly creates an individual right enforceable under Section 1983.
The court concluded that the language of Section 1396a(a)(23)(A) does not unequivocally create a right to choose any qualified provider, thus it does not support a Section 1983 action. The court distinguished this case from others by pointing to the Federal Nursing Home Reform Act, which explicitly grants individuals the right to select their personal attending physician, highlighting a clear legislative intent to create enforceable rights.
Additionally, the court noted that while Section 1983 lawsuits are crucial for protecting individual rights and ensuring state accountability, they can also divert state resources away from essential social services. The opinion emphasized that the authority to allow private enforcement of federal laws rests with Congress, not the judiciary, underscoring the importance of adhering to the separation of powers.
This ruling has significant implications for Medicaid recipients seeking services from Planned Parenthood and similar organizations, potentially reshaping the landscape of federally funded healthcare. The decision underscores the judiciary's deference to legislative clarity and congressional intent in interpreting laws that impact the provision of healthcare services across the United States.