SCOTUS Opinion 3/31/2015

The Supreme Court issued one decision today:

Armstrong v. Exceptional Child Center: By a vote of 5-4 the judgment of the Ninth Circuit is reversed.  Per Justice Scalia’s opinion for the Court, respondents lacked a right of action: “We consider whether Medicaid providers can sue to enforce §(30)(A) of the Medicaid Act….Respondents are providers of habilitation services to persons covered by Idaho’s Medicaid plan. They sued petitioners—two officials in Idaho’s Department of Health and Welfare—in the United States District Court for the District of Idaho, claiming that Idaho violates §30(A) by reimbursing providers of habilitation services at rates lower than §30(A) permits. They asked the court to enjoin petitioners to increase these rates. The District Court entered summary judgment for the providers, holding that Idaho had not set rates in a manner consistent with §30(A)…..The Ninth Circuit affirmed….It said that the providers had “an implied right of action under the Supremacy Clause to seek injunctive relief against the enforcement or implementation of state legislation.”…The ability to sue to enjoin unconstitutional actions by state and federal officers is the creation of courts of equity, and reflects a long history of judicial review of illegal executive action, tracing back to England. See Jaffe & Henderson, Judicial Review and the Rule of Law: Historical Origins, 72 L. Q. Rev. 345 (1956). It is a judge-made remedy, and we have never held or even suggested that, in its application to state officers, it rests upon an implied right of action contained in the Supremacy Clause. That is because, as even the dissent implicitly acknowledges, post, at 4 (opinion of SOTOMAYOR, J.) it does not. The Ninth Circuit erred in holding otherwise….The power of federal courts of equity to enjoin unlawful executive action is subject to express and implied statutory limitations. See, e.g., Seminole Tribe of Fla. v. Florida, 517 U. S. 44, 74 (1996). “‘Courts of equity can no more disregard statutory and constitutional requirements and provisions than can courts of law.’” INS v. Pangilinan, 486 U. S. 875, 883 (1988) (quoting Hedges v. Dixon County, 150 U. S. 182, 192 (1893); brackets omitted). In our view the Medicaid Act implicitly precludes private enforcement of §30(A), and respondents cannot, by invoking our equitable powers, circumvent Congress’s exclusion of private enforcement…..[T]he dissent speaks as though we leave these plaintiffs with no resort. That is not the case. Their relief must be sought initially through the Secretary rather than through the courts. The dissent’s complaint that the sanction available to the Secretary (the cut-off of funding) is too massive to be a realistic source of relief seems to us mistaken. We doubt that the Secretary’s notice to a State that its compensation scheme is inadequate will be ignored.”  Justice Scalia further concluded that the Medicaid Act itself did not imply a private right of action, though that claim had not been made and Justice Breyer did not join that portion of Justice Scalia’s opinion (Part IV).

Justice Scalia’s opinion for the Court was joined in full by the Chief Justice and Justices Thomas and Alito–and by Justice Breyer except as to Part IV.  Justice Breyer filed an opinion concurring in part and concurring in the judgment.  Justice Sotomayor dissented, joined by Justices Kennedy, Ginsburg, and Kagan.