Wilder v. Virginia Hospital Association (1989)
- Docket
- 88-2043
- Decided
- 1989-01-01
Summary
Question: Did the Boren Amendment create a "right" under the definition of 42 U.S.C. 1983, therefore allowing private parties to bring suit challenging the state's finding that its Medicaid reimbursement rates are "reasonable and adequate"? If such a right was created, did Congress intend to prevent private suits to enforce the it? Conclusion: Yes and no. In a 5-to-4 decision, the Court held that the Boren Amendment clearly established a right to reasonable and adequate reimbursement rates for the hospitals. Justice William J. Brennan, Jr., writing for the majority, stated that a right exists if "the provision in question was intend[ed] to benefit the ... plaintiff." The requirement of reasonable rates was clearly intended to benefit the hospitals, so it amounted to a right under 1983. Without explicit language within the Amendment preventing private suits under 1983, or an alternative remedial scheme that would make such suits unnecessary, it was not reasonable to conclude that Congress had intended to prevent private suits to enforce the right it had created.