Supreme Court of the United States

Douglas v. Independent Living Center of — Roberts, J…

February 22, 2012132 S. Ct. 1204

Summary

Justice Roberts, dissenting, argues that the Supremacy Clause does not create a private cause of action to enforce Medicaid reimbursement criteria because Congress did not intend such a remedy, and that the majority’s remand is unnecessary. He contends that the Ninth Circuit’s decision recognizing a Supremacy‑Clause cause of action should be reversed.