Armstrong v. Exceptional Child Center, Inc.

135 S.Ct. 1378 (2015)

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Nature of the Case

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Facts

Medicaid is a federal program. Congress provides federal funds in exchange for the States’ agreement to spend them in accordance with congressionally imposed conditions.

The State of Idaho adopted, and the Federal Government approved, a Medicaid “plan,” §1396a(a), which Idaho administers through its Department of Health and Welfare. Exceptional (P) are providers of habilitation services to persons covered by Idaho’s Medicaid plan. They sued Armstrong (D), two officials in Idaho’s Department of Health and Welfare, claiming that Idaho violates §30(A) by reimbursing providers of habilitation services at rates lower than §30(A) permits. Ps asked the court to enjoin Ds to increase these rates. The District Court entered summary judgment for Ps, holding that Idaho had not set rates in a manner consistent with §30(A). It ruled that the providers had “an implied right of action under the Supremacy Clause to seek injunctive relief against the enforcement or implementation of state legislation.” The Supreme Court granted certiorari.