Supreme Court Clarifies Limits on Private Lawsuits to Enforce Medicaid Rights: What Medina v. Planned Parenthood South Atlantic Means for Seniors

A landmark 2025 Supreme Court decision has significantly narrowed the ability of Medicaid beneficiaries,  including many seniors planning for long-term care or aging in place, to sue state agencies in federal court when they believe their benefits have been wrongly denied or restricted.  
In Medina v. Planned Parenthood South Atlantic, the Court held in a 6-3 opinion written by Justice Neil Gorsuch that the Medicaid Act’s “any-qualified-provider” provision (also known as the free-choice-of-provider clause) does not create an individually enforceable right that beneficiaries can sue to protect under 42 U.S.C. § 1983.  Section 1983 allows individuals to sue state or local government officials or entities in federal court when those officials violate a person's constitutional rights or certain federal statutory rights. In simple terms,  if a government actor (like a police officer, prison official, or state agency) deprives you of your constitutional rights, you can use Section 1983 to sue them for damages or to stop the violation.
The case arose when South Carolina excluded Planned Parenthood clinics from its Medicaid program because the clinics provide abortion services. Medicaid beneficiaries who wanted to continue receiving care from those clinics sued the state under § 1983, arguing that the exclusion violated their statutory right to choose any qualified provider willing to participate in the program.  The lower courts (including the Fourth Circuit) had sided with the beneficiaries, allowing the lawsuit to proceed. The Supreme Court reversed that decision.
Before Medina, federal courts were split on whether Medicaid beneficiaries could bring private lawsuits to enforce various provisions of the Medicaid Act. Several circuits, most notably the Fourth, Ninth, and others following earlier precedents, had been leaning toward permitting such private § 1983 actions for provisions like free choice of provider and “reasonable promptness” in delivering services. These courts viewed certain Medicaid language as creating clear, individual rights.
The Supreme Court in Medina rejected that approach. It reaffirmed and strengthened the demanding test from Gonzaga University v. Doe (2002) and Health and Hospital Corp. of Marion County v. Talevski (2023): Spending-power statutes like Medicaid create privately enforceable rights only in rare, atypical cases where Congress uses unmistakably clear “rights-creating” language focused on individual beneficiaries rather than on the states.
The Medicaid Act, the Court explained, is fundamentally a bargain between the federal government and the states. The primary enforcement mechanism is the federal government’s ability to withhold funding from non-compliant states, not private lawsuits by beneficiaries. As a result, most provisions of the Medicaid Act (including free choice of provider) do not support individual federal-court actions.What This Means for Seniors and Elder Law Planning
For older adults and families planning for nursing home care, in-home services, or long-term care coverage through Medicaid, the practical impact is significant:

• Challenges to state Medicaid decisions (denials, delays, or provider restrictions) are now more likely to be confined to state administrative appeal processes.
• Federal-court remedies under § 1983 are much harder to obtain.
• Careful upfront planning becomes even more important. Once you apply for Medicaid, your ability to fight an adverse decision in federal court is now more limited.

This ruling reinforces that Medicaid eligibility and coverage disputes are primarily administrative and state-level matters. Families should work proactively with an elder law attorney to structure assets, use trusts or other tools, and ensure compliance with current rules, well before a crisis arises.

If you have questions about how this decision might affect your Medicaid planning, long-term care options, or aging-in-place strategy, schedule a consultation with a qualified elder law attorney. A thorough plan today can help protect your choices and security tomorrow. 

The "Residents' Bill of Rights" is NOT the Residents'-- Federal Nursing Home Act Creates NO Private Causes of Action

A Federal District Court has ruled that the Federal Nursing Home Reform Act, which among other things requires the provision of certain services to each resident, does not create a private cause of action.  The Act is most widely known for creating the Residents' Bill of Rights, but apparently, the right to seek redress for injury or loss resulting from the failure of a nursing home to enforce these rights is not among them.

The Plaintiff, Joanne Fiers' filed a claim after the death of her brother, Richard Bendel, while he was a resident at Lakeview Health Center in West Salem, Wisconsin. Bendel, suffered from severe dementia and was a known elopement risk; he therefore required increased supervision.  Bendell left the facility unattended, fell and suffered injuries that led to his death in February 2014.  A certified nursing assistant watched Bendel walking toward one of the facilities exits, but failed to do anything to prevent his leaving.  Two other certified nursing assistants allegedly ignored an audible door alarm as Bendel exited the facility. After he exited, Bendel walked across a roadway, tripped on a curb, and fell, sustaining critical injuries from which he would succumb four days later.  

Several days later, the Wisconsin Department of Health and Human Services investigated the "elopement incident."  The facility was cited with an "Immediate Jeapardy Violation."  

In addition to seeking compensatory and punitive damages for pain and suffering as a result of the nursing home's negligence, Fiers also alleged that Lakeview violated Bendel's resident rights under Section 1983, rights set forth in the  Federal Nursing Home Reform Act (which includes but is not limited to the Residents' Bill of Rights).

The U.S. District Court for the Western District of Wisconsin ruled Section 1983 does not create a right of redress because FNHRA does not create private, enforceable rights for residents, and further that Fiers' complaint failed to identify specifically the rights that Lakeview violated. In order to allege a deprivation of rights under the FNHRA, the court ruled that Fiers was required to show that FNHRA was meant to benefit residents in a way that was not  “vague and amorphous."  No penumbra of a right to adequate health care, or a logical extension of rights and remedies, is countenanced by the court's opinion.

The Act, the court explained, was written to describe what a nursing home has to do to receive government funding, not what rights it is required to provide residents. Apparently the "Residents' Bill of Rights," would have more aptly been called, the "Nursing Homes' Obligations For Federal Funding Without Regard to Residents' Rights, Privileges, or Redress."  Yes, that is much clearer.  

The court granted Lakeview's motion to dismiss Fiers'  Section 1983 complaint.

The Plaintiff will, of course, continue to pursue her claims for negligence against the facility, but will have to do so in state, rather than federal court. In some states, citations against a nursing home for violating standards of care are not admissible in court.        

To read the court's opinion, go here.

To read the McKnight's article about the case, go here.