BlogLine

Medina v. Planned Parenthood: A turning point for §1983 claims?

7/23/25

By: Xander D. Melnick

In Medina v. Planned Parenthood South Atlantic, 606 U.S. ___ (2025), the United States Supreme Court issued a significant decision that further narrows the scope of private enforcement under 42 U.S.C. §1983. The case arose from South Carolina’s decision to exclude Planned Parenthood from its Medicaid program, prompting a challenge under §1983 by Planned Parenthood and a Medicaid recipient. The plaintiffs argued that the exclusion violated the Medicaid Act’s “any-qualified-provider” provision, codified at 42 U.S.C. §1396a(a)(23)(A), which they contended conferred an enforceable individual right. 

At its core, Medina addresses a fundamental question about the reach of §1983: does the statute’s reference to “rights, privileges or immunities secured by the Constitution and laws” include rights created by federal statutes, particularly those enacted under the Spending Clause? More specifically, the Court was asked to decide whether Medicaid’s “any-qualified-provider” provision creates an individually enforceable federal right under §1983. 

The Court, in a 6–3 decision authored by Justice Gorsuch, held that the “any-qualified-provider” provision does not “clearly and unambiguously” create an individual right. The majority emphasized that Spending Clause statutes, such as Medicaid, function as contracts between the federal government and the states. As such, they do not typically create judicially enforceable rights unless Congress has spoken with unmistakable clarity. The Court reaffirmed the stringent standard articulated in Gonzaga University v. Doe and Health & Hospital Corp. v. Talevski, requiring that a statute contain “rights-creating language” and reflect congressional intent to create individually enforceable rights. The Court rejected reliance on cases like Wilder v. Virginia Hospital Assn., Wright v. Roanoke Redevelopment and Housing Authority and Blessing v. Freestone, which suggested less demanding standards than Talevski. It explained that Congress knows how to create clear rights by using specific language such as “the right to,” “guarantee” or “free choice.” The Medicaid provision at issue failed to include this language and thus, the Court concluded, failed to meet the threshold. 

Justice Thomas authored a concurring opinion that went further than the majority’s reasoning. He reiterated his longstanding critique of the Court’s §1983 jurisprudence, arguing that the modern framework is inconsistent with the statute’s original meaning and historical context. In his view, §1983 was never intended to authorize private enforcement of federal statutes, particularly those enacted pursuant to the Spending Clause. Thomas contended that courts should not infer private rights of action absent explicit congressional authorization, and he called for a fundamental reexamination of the doctrine. 

The implications of Medina are substantial. The decision reinforces a high bar for plaintiffs seeking to enforce federal statutory provisions through §1983. It signals a continued judicial reluctance to recognize implied rights of action under Spending Clause legislation. For litigators, this ruling necessitates a careful examination of statutory language and strategic reassessment of claims brought under §1983.  

Justice Thomas’s concurrence suggests a potential future trajectory in which the Court may further curtail or even eliminate private enforcement of federal statutes under §1983. While the majority did not adopt his broader critique, his opinion underscores a growing skepticism within the Court regarding the judicial role in implying private rights of action. As such, Medina may represent not only a doctrinal tightening but also a precursor to more fundamental changes in §1983 jurisprudence. 

If you have any questions about the Medina case or §1983 claims, please contact attorney Xander D. Melnick at xander.melnick@fmglaw.com or any of the attorneys in FMG’s Government Law Section.  

Information conveyed herein should not be construed as legal advice or represent any specific or binding policy or procedure of any organization. Information provided is for educational purposes only. These materials are written in a general format and not intended to be advice applicable to any specific circumstance. Legal opinions may vary when based on subtle factual distinctions. All rights reserved. No part of this presentation may be reproduced, published or posted without the written permission of Freeman Mathis & Gary, LLP.