Armstrong v. Exceptional Child Center, Inc.

**Question presented** Do Medicaid providers have a “private right of action” – that is, the ability to sue a state – under the Constitution’s Supremacy Clause in order to force Idaho to set reimbursement rates that meet the Medicaid‑Act requirement in §30(A) that payments be efficient, economical and of sufficient quality? **Holding** The Supreme Court said **no**. The Supremacy Clause does not give private parties a cause of action, and the providers cannot obtain an injunction (a court order requiring the state to raise the rates) to enforce §30(A). The lower‑court judgment is reversed. **Why the Court reached that result** 1. **What the Supremacy Clause does** – It simply tells courts that when a federal law and a state law conflict, the federal law wins. The Court said the text contains no language that creates a new right for individuals to go to court and enforce federal law. Historically and in prior cases the Clause has never been understood that way. 2. **Congress’s control over enforcement** – Because the Medicaid program is a spending‑power law, Congress decides how violations are to be remedied. The statute already provides a specific remedy: the federal government can withhold Medicaid funds from a state that fails to comply (§1396c). By providing that single remedy and by the complexity of supervising state reimbursement rates, Congress signaled that courts should not be used for equitable relief such as injunctions. 3. **Limits on equitable relief** – The Court noted that federal courts can only issue injunctions against unlawful executive actions when Congress has expressly or implicitly allowed it. Here, the express statutory remedy (withholding funds) and the congressional intent to “foreclose” other court‑ordered relief mean that equity courts lack the authority to grant the providers the injunction they sought. **Vote** Justice Scalia wrote the majority opinion. Chief Justice Roberts, and Justices Thomas, Breyer and Alito joined the majority for Parts I‑III; for Part IV the majority consisted of Scalia, Roberts, Thomas and Alito. Justice Breyer filed a partial concurrence, and Justice Sotomayor wrote a dissent joined by Justices Kennedy, Ginsburg and Kagan. The overall split was 5‑4 in favor of the majority.