Thursday, January 31, 2013

Douglas v. Indep. Living Ctr. of S. Cal., Inc. case brief

Douglas v. Indep. Living Ctr. of S. Cal., Inc.
132 S. Ct. 1204

Respondent Medicaid providers and recipients brought suits against petitioner California state officials pursuant to the Supremacy Clause, seeking to enjoin implementation of California statutes that reduced payments to providers under the state's Medicaid plan. The United States Court of Appeals for the Ninth Circuit affirmed or ordered preliminary injunctions preventing implementation of the statutes. The Supreme Court granted certiorari.

-Respondents argued that the state rate reductions were preempted by 42 U.S.C.S. § 1396a(a)(30)(A) because California had not shown that its Medicaid plan, as amended, would enlist enough providers to make Medicaid care and services sufficiently available.
-While the matter was pending before the Supreme Court, the Centers for Medicare and Medicaid Services (CMS) approved several of the statutory amendments to California's plan as consistent with federal law.


In light of the changed circumstances, it was necessary to determine whether respondents' claims could proceed directly under the Supremacy Clause or whether respondents were required to seek review of CMS's determination under the Administrative Procedure Act (APA), 5 U.S.C.S. § 701 et seq.

-Respondents' challenge presented the kind of legal question that ordinarily called for APA review, and allowing a Supremacy Clause action to proceed after CMS had reached a decision threatened potential inconsistency or confusion. Remand was warranted because the parties had not fully addressed the question of whether a Supremacy Clause action was appropriate after the agency had acted.

OUTCOME: The Ninth Circuit's judgments were vacated, and the cases were remanded. 5-4 decision; 1 dissent.

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