Douglas v. Independent Living Center of Southern California, Inc., et al.
United States Supreme Court
132 S.Ct. 1204 (2012)
States must submit Medicaid plan amendments to the federal Centers for Medicare & Medicaid Services (CMS) for approval. In 2008-2009, California passed statutes cutting Medicaid provider payments and sent them to CMS for review. Before CMS finished reviewing, several plaintiffs sued Toby Douglas, the state's health-care director (defendant), in federal court, arguing the Supremacy Clause let them block the cuts as preempted by federal Medicaid law. The Ninth Circuit consolidated the suits and struck down the amendments as preempted. While the case was pending before the Supreme Court, CMS approved several of the amendments as consistent with federal law; the parties agreed the case was still live.
Whether the Supremacy Clause provides a private cause of action to challenge a state's change to Medicaid benefits once the appropriate federal agency has approved that change.