Supreme Court Rules South Carolina Can Exclude Planned Parenthood from Medicaid, 6-3
On June 26, 2025, the U.S. Supreme Court ruled 6-3 that a Medicaid patient may not sue to challenge South Carolina's exclusion of Planned Parenthood from the state's Medicaid program. The case began with the state government in Columbia, Richland County, South Carolina: in 2018, Governor Henry McMaster ordered the state Department of Health and Human Services to deem clinics that provide abortion services unqualified, and to terminate their Medicaid participation.
Planned Parenthood South Atlantic, which operates two clinics in the state, and patient Julie Edwards sued state officials under the Medicaid Act's any-qualified-provider provision, which provides that eligible individuals may obtain services from any provider qualified to perform them. The district court and the U.S. Court of Appeals for the Fourth Circuit ruled for the plaintiffs and enjoined the exclusion.
Writing for the majority, Justice Neil Gorsuch said that for a federal spending statute to confer a right enforceable by private suit, its text must use clear and unambiguous rights-creating language with an unmistakable focus on the individual benefited. The any-qualified-provider provision, 42 U.S.C. 1396a(a)(23)(A), does not meet that test, the Court held, so it creates no individual right enforceable under 42 U.S.C. 1983, and the Fourth Circuit's judgment was reversed.
Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Brett Kavanaugh, and Amy Coney Barrett joined the majority, and Thomas also wrote a concurrence. Justice Ketanji Brown Jackson dissented, joined by Justices Sonia Sotomayor and Elena Kagan, arguing that the provision's wording should not bar patients from defending their choice of provider.
The case is Medina v. Planned Parenthood South Atlantic, No. 23-1275. As a direct result, South Carolina may keep Planned Parenthood excluded from its Medicaid program; a number of other states have previously sought to exclude the organization from their Medicaid programs, and those efforts will now turn more on the funding relationship between state and federal governments than on suits by individual patients.
(Source: Supreme Court of the United States)
Source: Supreme Court of the United States
Published by GSM · USA (original Chinese edition)
Photo: 图：位于 Columbia 的南卡罗来纳州议会大厦，本案起于该州州政府将计划生育组织排除出州医疗补助的决定。w_lemay 摄，CC BY-SA 2.0，经 Wikimedia Commons。 / Photo: The South Carolina State House in Columbia; the case began with the state government's decision to exclude Planned Parenthood from the state Medicaid program. Photo by w_lemay, CC BY-SA 2.0, via Wikimedia Commons.
