Armstrong v. Exceptional Child Center, Inc.

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Constitutional Law
  • Date Filed: March 31, 2015
  • Case #: 14-15
  • Judge(s)/Court Below: Scalia , J., delivered the opinion of the Court with respect to Parts I, II, and III, in which Roberts, C.J., and Thomas, Breyer, and Alito, JJ., joined, and an opinion with respect to Part IV, in which Roberts,, C J., and Thomas and Alito , JJ., joined. Breyer, J., filed an opinion concurring in part and concurring in the judgment. Sotomayor , J., filed a dissenting opinion, in which Kennedy, Ginsburg, and Kagan, JJ., joined.
  • Full Text Opinion

A Medicaid provider does not have a private right of action to sue under the Medicaid Act because the Supremacy Clause does not give the right to do so.

In 2005, the Idaho state legislature passed a law requiring the state Medicaid agency to implement a new methodology to determine provider reimbursement rates, and in 2009, the state Medicaid agency published new, higher rates based on cost studies conducted under the new methodology. The Centers for Medicare and Medicaid Services (CMS) approved the state’s new methodology in a waiver amendment. However, the new rates were not implemented because the state legislature failed to appropriate sufficient funding. Respondents argued that health providers have a right under the Supremacy Clause of the U.S. Constitution to challenge state funding levels that are so low they conflict with the federal Medicaid Act's 'reasonable reimbursement' requirement.

The Supreme Court vacated and reversed the lower court's decision, and held that the Supremacy Clause does not provide an implied right of action, and that respondents could not sue under a private right to enforce federal Medicaid funding laws against states since Congress has not created such a right to do so.

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