Today the Supreme Court upheld long-standing precedent that protects the right to file suit in federal court against State and local agencies whose practices violate rights supplied by the U.S. Constitution and federal laws. Federally qualified health centers’ (FQHC) ability to sue to enforce their statutory right to full Medicaid reimbursement hung in the balance while the case was considered. In Health and Hospital Corporation of Marion County v. Talevski, 599 U.S. ___ (2023), Justice Jackson, writing for a majority of seven Justices, assured FQHCs and others who enjoy Congressionally-conferred rights that “…as we have previously held, [42 U.S.C.] § 1983 can presumptively be used to enforce unambiguously conferred federal individual rights…we affirm the lower court’s judgment that respondent’s § 1983 action can proceed in court.”
Section 1983 makes federal courts available to persons and organizations whose federal legal rights have been infringed by State officials “acting under color of law.” The statute, initially enacted as part of the Civil Rights Act of 1871, “reflected the regrettable reality that ‘state instrumentalities’ could not, or would not, fully protect federal rights.” In Talevski, a nursing home patient filed a § 1983 case in federal court to enforce Medicaid patient rights against unlawful practices at a county-run facility. The Supreme Court held that nursing home patients may file a § 1983 action to enforce their rights under the Federal Nursing Home Reform Act (FNHRA) provisions in the Medicaid statute against illegal nursing home practices. Although decided in the context of FNHRA, Talevski reaffirms that § 1983 actions are available to protect all unambiguously conferred Medicaid Program rights against state violations.
For decades, FQHCs have vindicated their Medicaid payment rights through legal actions filed under § 1983 in federal courts and obtained critical relief against unlawful State agency payment practices. The Court’s decision in Talevski ensures that federal courthouse doors remain open to protect these and other specific rights contained in both the Medicaid statute and other laws Congress authorizes pursuant to its Spending Clause powers. The Talevski opinion may be accessed here.