Westside Mothers v. Haveman case brief

Westside Mothers v. Haveman case brief summary
289 F.3d 852 (2002)

CASE SYNOPSIS

Plaintiff professional organizations, advocacy organizations, and individuals sued defendant state officials in the United States District Court for the Eastern District of Michigan under 42 U.S.C.S. § 1983, alleging a failure to provide services required by the Medicaid Act, 42 U.S.C.S. § 1396 et seq. The district court dismissed the suit. All plaintiffs except for one advocacy organization appealed.

CASE FACTS
Plaintiffs claimed that the state officials did not provide screening, diagnostic, and treatment services mandated by 42 U.S.C.S. § 1396d of the Medicaid Act.

DISCUSSION

• The appellate court held that dismissal was erroneous, as 
• (1) the Medicaid program was not merely a contract, and its provisions were binding upon participating states; 
• (2) laws validly passed by Congress under its spending powers were supreme law of the land; 
• (3) sovereign immunity did not bar the suit because plaintiffs' claims of an ongoing violation of federal law and request for injunctive relief brought the action within Ex parte Young; and 
• (4) plaintiffs had a private right of action under § 1983 to enforce the Medicaid provisions in question. 
• The district court also erred in finding that two professional organizations lacked standing to sue. 
• The organizations alleged an injury to their members due to reduced payments caused by the limitation in Medicaid services, and that injury was traceable to the state officials' actions and could be redressed through a favorable decision. 
• Dismissal was proper as to an advocacy organization that provided too little information in the complaint to establish standing.

CONCLUSION
The district court's dismissal of one advocacy organization was affirmed. The judgment was otherwise reversed and remanded.


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