Supreme Court of the United States

Douglas v. Independent Living Center of Southern…

February 22, 2012132 S. Ct. 1204

Summary

Court vacated and remanded after CMS approved state Medicaid rate reductions, suggesting APA review may be more appropriate than Supremacy Clause actions post-agency approval, without deciding the underlying cause of action question. Chief Justice Roberts dissented, arguing Supremacy Clause does not provide private cause of action where statute does not.