U.S. Supreme Court

Case Status


Docket Number


2014 Term


Questions Presented

Whether the Supremacy Clause gives Medicaid providers a private right of action to enforce 42 U.S.C. § 1396a(a)(30)(A) against a state where Congress chose not to create enforceable rights under that statute; and (2) whether, if Medicaid providers have a private right of action, a state’s Medicaid provider reimbursement rates are preempted by 42 U.S.C. § 1396a(a)(30)(A) where they do not bear a reasonable relationship to provider costs and remain in place for budgetary reasons.

Case Updates

U.S. Supreme Court concludes that the Supremacy Clause does not confer a private right of action.

March 31, 2015

The judgment of the Ninth Circuit is reversed. The Court issued a 5-4 judgement that the Supremacy Clause does not confer a private right of action, and that Medicaid providers cannot sue for an injunction requiring compliance with §30(a).

U.S. Chamber files amicus brief

December 24, 2014

In its brief, the U.S. Chamber asked the U.S. Supreme Court to affirm the judgment of the Ninth Circuit holding that individuals and businesses injured by unconstitutional state legislation retain the right to seek prospective equitable relief in federal court, regardless of what remedies might be available to the federal government to vindicate its own interests in enforcing federal law.

The brief argues that robust enforcement of the Supremacy Clause is necessary to protect against state and local mandates that interfere or conflict with federal law. Petitioners seek to weaken or eliminate a significant, time-tested method for such enforcement: the cause of action for equitable relief arising directly under the Supremacy Clause. The brief goes on to point out that two centuries of Supreme Court precedent support a right of action to enjoin state legislation that is valid under the Supremacy clause. The petitioners offer no persuasive reason why the preemption claims arising under the Supremacy Clause should be called into question. It is “well-established” that the Constitution itself supports a right of action seeking prospective equitable relief to address constitutional violations.

Carter G. Phillips, Peter D. Keisler, Quin M. Sorenson, and Lowell J. Schiller of Sidley Austin LLP represented the U.S. Chamber of Commerce as co-counsel to the U.S. Chamber Litigation Center.

Case Documents