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DOUGLAS v. INDEPENDENT LIVING CENTER OF SOUTHERN CALIFORNIA

Docket No.: 09-958
Certiorari Granted: 1/18/2011
Argued: October 3, 2011
Decided: February 22, 2012
Consolidated with: 09-115810-283

Topics:

Administrative Procedure, Article I, Commerce Clause, Due Process, EPA, Eleventh Amendment, Medicaid, Medicaid reimbursement rates, Medicare, Natural Resources, Supremacy Clause, Takings Clause, abuse of discretion, equitable relief, judicial review, preemption, preliminary injunction, separation of powers, sovereign immunity

PartyNames: Toby Douglas, Director, California Department of Health Care Services v. Independent Living Center of Southern California, Inc., et al.
Petitioner: Toby Douglas, Director, California Department of Health Care Services
Respondent: Independent Living Center of Southern California, Inc., et al.

Court Below: United States Court of Appeals for the Ninth Circuit
Citation: 572 F.3d 644

Toby Douglas, Director, California Department of Health Care Services
v.
Independent Living Center of Southern California, Inc., et al.
Background:

Under 42 U.S.C. § 1396a(a)(30)(A) of the Medicaid Act, a state that accepts federal Medicaid funds must adopt a state plan containing methods and procedures to "safeguard against unnecessary utilization of .. . [Medicaid] services and . . . assure that payments are consistent with efficiency, economy, and quality of care and are sufficient to enlist enough providers so that care and services are available . . . at least to the extent that such care and services are available to the general population." The Ninth Circuit, along with virtually all of the circuits to have considered the issue since this Court's decision in Gonzaga University v. Doe, 536 U.S. 273 (2002), concluded that this provision does not confer any "rights" on Medicaid providers or recipients that are enforceable under 42 U.S.C. § 1983, and respondents do not contend otherwise. Nonetheless, in the present case, the Ninth Circuit held that § 1396a(a)(30)(A) preempted a state law reducing Medicaid reimbursement payments because the State failed to produce evidence that it had complied with requirements that do not appear in the text of the statute, and because the reductions were motivated by budgetary considerations.

Consideration Limited:

LIMITED TO QUESTION 1 PRESENTED BY THE PETITIONS. THE PARTIES AND THE SOLICITOR GENERAL ARE DIRECTED TO FILE SUPPLEMENTAL BRIEFS ADDRESSING THE FOLLOWING QUESTION: "WHAT SHOULD BE THE EFFECT, IF ANY, OF THE DEVELOPMENTS DISCUSSED IN THE LETTER SUBMITTED BY THE SOLICITOR GENERAL ON OCTOBER 28, 2011, ON THE PROPER DISPOSITION OF THIS CASE?"

Question Presented:

1. Whether Medicaid recipients and providers may maintain a cause of action under the Supremacy Clause to enforce § 1396a(a)(30)(A) by asserting that the provision preempts a state law reducing reimbursement rates? 2. Whether a state law reducing Medicaid reimbursement rates may be held preempted by § 1396a(a)(30)(A) based on requirements that do not appear in the text of the statute?

Question:

Does federal law preempt state reductions in Medicaid payments?

DOUGLAS v. INDEPENDENT LIVING CENTER OF SOUTHERN CALIFORNIA
ORAL ARGUMENT

October 3, 2011

Listen to Oral Argument in DOUGLAS v. INDEPENDENT LIVING CENTER OF SOUTHERN CALIFORNIA
Holding: vacated and remanded
Vote: 5-4
Opinion By:
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