Supreme Court of the United States

Richard Armstronget Al., Petitioners v. Exceptional Child Center, Inc.

March 31, 2015575 U.S. 320

Summary

In a five-to-four judgment authored by Justice Scalia (except as to Part IV), the Supreme Court reversed the Ninth Circuit and held that Medicaid providers cannot maintain an officer-enjoining equitable suit to compel Idaho to raise habilitation-service reimbursement rates under § 30(A) of the Medicaid Act. The Court ruled that the Supremacy Clause is a rule of decision for courts but is not a source of federal rights and creates no cause of action, and that Congress implicitly foreclosed private equitable enforcement of § 30(A) by vesting enforcement exclusively in the Secretary of Health and Human Services through fund withholding and by drafting § 30(A) as a broad, judgment-laden standard unsuited to judicial administration; § 30(A) also lacks the rights-creating language needed for an implied statutory action. Justice Breyer joined Parts I-III and concurred in the judgment, stressing the nonjudicial nature of rate-setting, while Justice Sotomayor, joined by Kennedy, Ginsburg, and Kagan, dissented on the ground that the identified statutory features fall far short of the detailed remedial scheme she deemed necessary to establish congressional foreclosure of traditionally available equitable relief.

Holding

  • Whether the Supremacy Clause creates a cause of action for private suits enjoining state officers who act contrary to federal law.. No. The Supremacy Clause creates a rule of decision for courts but is not the source of any federal rights and certainly does not create a cause of action; the Ninth Circuit erred in treating preemption injunctions against state officers as resting on an implied right of action contained in the Supremacy Clause.
  • Whether respondents may proceed against Idaho in equity although Congress has provided an administrative enforcement mechanism for § 30(A).. No. The Medicaid Act implicitly precludes private enforcement of § 30(A), and respondents cannot, by invoking the courts' equitable powers, circumvent Congress's exclusion of private enforcement; two aspects of § 30(A) establish Congress's 'intent to foreclose' equitable relief—the Secretary's withholding of funds as the sole provided remedy for noncompliance, and the judicially unadministrable breadth of § 30(A)'s judgment-laden standard committed to agency expertise.
  • Whether the Medicaid Act itself confers a private right of action on providers to enforce § 30(A).. No. Section 30(A) lacks the sort of rights-creating language needed to imply a private right of action; it is phrased as a directive governing the Secretary's approval of state Medicaid plans, not as a conferral of sueable rights on beneficiaries, and nothing in the Act unambiguously confers such a right.

Docket 14-15

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