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Armstrong v. Exceptional Child Center, Inc.

Docket No.: 14-15
Argued: January 20, 2015
Decided: 3/31/15

Topics:

Appointments Clause, Article I, EPA, Eleventh Amendment, Federalism, Medicaid, Medicare, NLRA, Natural Resources, Social Security Act, Supremacy Clause, abuse of discretion, equitable relief, judicial review, preemption

PartyNames: Richard Armstrong, et al. v. Exceptional Child Center, Inc., et al.
Petitioner: Richard Armstrong, et al.
Respondent: Exceptional Child Center, Inc., et al.

Court Below: United States Court of Appeals for the Ninth Circuit
Citation: 567 Fed.Appx. 496
Supreme Court Docket

Richard Armstrong, et al.
v.
Exceptional Child Center, Inc., et al.
Background:

To receive federal Medicaid funding, a state must adopt a plan containing "methods and procedures" that will "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 ..." 42 U.S.C. 1396a(a)(30)(A). Congress chose not to confer on Medicaid providers any enforceable rights under this statute. The Ninth Circuit in this case, however, held that (a) Medicaid providers could enforce Section 1396a(a)(30)(A) directly under the Supremacy Clause; and (b) the State of Idaho's Medicaid reimbursement rates were preempted by that statute because they did not "substantially reimburse providers their costs" and because they remained in place "for purely budgetary reasons."

Consideration Limited:

LIMITED TO QUESTION 1 PRESENTED BY THE PETITION.

Question Presented:

1. Does the Supremacy Clause give Medicaid providers a private right of action to enforce Section 1396a(a)(30)(A) against a state where Congress chose not to create enforceable rights under that statute? 2. If Medicaid providers have a private right of action, are a state's Medicaid provider reimbursement rates preempted by Section 1396a(a)(30)(A) where they do not bear a reasonable relationship to provider costs and remain in place for budgetary reasons?

Armstrong v. Exceptional Child Center, Inc.
ORAL ARGUMENT

January 20, 2015

Listen to Oral Argument in Armstrong v. Exceptional Child Center, Inc.
Holding: REVERSED
Vote: 5-4
Majority: Judgment Reversed. Scalia, Chief Justice Roberts, Thomas, Breyer, Alito
Concurring: Breyer
Dissenting: Sotomayor,Kennedy,Ginsburg,Kagan
Opinion By:
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