Medina v. Planned Parenthood
Case Overview
Planned Parenthood South Atlantic v. Medina is the district court case from South Carolina that gave rise to the Supreme Court's decision in Medina v. Planned Parenthood South Atlantic (2025). South Carolina's governor directed the state Medicaid agency to exclude Planned Parenthood from the Medicaid provider network; Planned Parenthood and patient-plaintiffs sued in the District of South Carolina. The district court ruled for Planned Parenthood, finding the Medicaid Act's free-choice-of-provide
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The Facts
South Carolina issued an executive order directing the Department of Health and Human Services to exclude Planned Parenthood South Atlantic from its Medicaid network. Planned Parenthood filed suit as both a provider and on behalf of patient-plaintiffs, arguing the exclusion violated 42 U.S.C. Section 1396a(a)(23), which requires state Medicaid plans to allow beneficiaries to obtain services from any qualified provider. The district court issued a preliminary injunction. The Fourth Circuit affirmed. South Carolina sought SCOTUS review.
The Application
Applying the Gonzaga standard for private rights of action under § 1983, the district court examined whether § 1396a(a)(23) created an individually enforceable right. The court found that the statute's clear language requiring states to permit beneficiaries to obtain services from any qualified provider established such a right, and accordingly issued a preliminary injunction in Planned Parenthood's favor; the Fourth Circuit affirmed. The Supreme Court reversed in 2025, holding that the free-choice provision, despite its mandatory terms, does not create a private right of action enforceable under § 1983.
The Conclusion
This is the district court origin case for what became Medina v. Planned Parenthood South Atlantic at SCOTUS. The Supreme Court's 6-3 reversal in 2025 controls. See entry for SC v. John Doe (25A234) for full FIRAC on the Supreme Court decision.
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