United States Supreme Court

Respondents, providers of habilitation services, sued petitioners, Idaho Health and Welfare Department officials, claiming that Idaho reimbursed them at rates lower than section 30(a) of the Medicaid Act permits. Respondents sought to enjoin petitioners to increase these rates. The District Court entered summary judgment for respondent-providers, and the Ninth Circuit affirmed, concluding that the Supremacy Clause gave the providers an implied right of action, and that they could sue under this implied right of action to seek an injunction requiring Idaho to comply with section 30(a). The judgment of the Ninth Circuit is reversed, where: 1) the Supremacy Clause does not confer a private right of action; 2) the Supremacy Clause instructs courts to give federal law priority when state and federal law clash, but it is not the source of any federal rights and does not create a cause of action; and 3) Medicaid providers cannot sue for an injunction requiring compliance with section 30(a).

Appellate Information

• Decided 03/31/2015
• Published 03/31/2015

Judges

• Scalia

Court

• United States Supreme Court

Counsel