Law School Case Brief
Armstrong v. Exceptional Child Ctr., Inc. - 135 S. Ct. 1378 (2015)
It is apparent that U.S. Const. art. VI, cl. 2, creates a rule of decision: Courts shall regard the United States Constitution, and all laws made in pursuance thereof, as the supreme law of the land. They must not give effect to state laws that conflict with federal laws. It is equally apparent that the Supremacy Clause is not the source of any federal rights and certainly does not create a cause of action. It instructs courts what to do when state and federal law clash, but is silent regarding who may enforce federal laws in court, and in what circumstances they may do so.
Providers of habilitation services under Idaho's Medicaid plan were reimbursed by the State's Department of Health and Welfare. Section 30(A) of the Medicaid Act required Idaho's plan to “assure that payments are consistent with efficiency, economy, and quality of care” while “safeguarding against unnecessary utilization of care and services.” Exceptional Child Center, Inc., et al., providers of habilitation services, sued Idaho Health and Welfare Department officials, claiming that Idaho reimbursed them at rates lower than §30(A) permits, and sought to enjoin the officials so they would increase these rates. The District Court entered summary judgment for the providers. 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 §30(A).
Could the providers of habilitation services sue under an alleged implied right of action?
The Court held that the ability to sue to enjoin unconstitutional actions by state and federal officers was a judge-made remedy and judicial precedent did not hold or even suggest that, in its application to state officers, it rested upon an implied right of action contained in the Supremacy Clause, U.S. Const. art. VI, cl. 2. According to the Court, the sheer complexity associated with enforcing § 30(A) of the Medicaid Act, coupled with the express provision of an administrative remedy, showed that the Medicaid Act precluded private enforcement of § 30(A) in the courts. The judgment was reversed.
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