Supreme Court ruled 6-3 Medicaid patients cannot sue to enforce free-choice-of-provider, clearing path to exclude Planned Parenthood

On June 26, 2025, the Supreme Court ruled 6-3 in Medina v. Planned Parenthood South Atlantic that Medicaid enrollees cannot use 42 U.S.C. § 1983 to enforce the program's free-choice-of-provider provision in federal court. Justice Gorsuch wrote for the majority — Roberts, Thomas, Alito, Kavanaugh, and Barrett — holding that the provision's requirement that states allow enrollees to choose "any qualified" provider imposes a duty on states without conferring an individual "right" cognizable under § 1983. The case arose from South Carolina's 2018 executive order barring Medicaid patients from receiving non-abortion services — contraception, STI testing, and cancer screenings — from Planned Parenthood clinics.

Section 1983 is the principal federal civil rights statute that allows individuals to sue state governments for denying federally protected rights. Before this ruling, Planned Parenthood and individual Medicaid patients had used § 1983 suits to block exclusion orders in multiple states, with federal courts consistently finding the free-choice provision created enforceable rights. At least 14 states had enacted or attempted similar exclusion orders that had been stopped in court through this mechanism; South Carolina's order had been blocked since it was first issued in 2018.

Justice Jackson's dissent, joined by Kagan and Sotomayor, argued that the majority's reading converts a rights-granting statute into an unenforceable state obligation, effectively rendering the free-choice provision without legal force for the patients it was meant to protect. Healthcare policy analysts at the Kaiser Family Foundation projected the ruling would accelerate exclusion orders in states with pending restrictions, with particular impact on low-income patients in rural areas who rely on Planned Parenthood as their only affordable source of reproductive and preventive healthcare. The ruling came as Congress was advancing reconciliation legislation that would federally defund Planned Parenthood in all 50 states.

The Court's decision eliminates the judicial backstop that previously deterred states from excluding Medicaid patients' chosen providers without consequence. Without § 1983 as an enforcement mechanism, the free-choice-of-provider guarantee becomes effectively unenforceable by individual patients, leaving low-income Americans dependent on Medicaid with no individual remedy when states cut access to their providers.