Douglas v. Independent Living Center of Southern California (2011)
- Docket
- 09-958
- Decided
- 2011-01-01
Summary
Question: Does federal law preempt state reductions in Medicaid payments? Conclusion: Maybe. In a 5-4 decision Justice Stephan G. Breyer wrote the majority opinion vacating the judgment and remanding to the Ninth Circuit. Since the court granted certiorari, the federal Centers for Medicare & Medicaid Services (CMMS) approved many of the cutbacks as consistent with federal law. California withdrew all cutbacks that were not approved. In light of this development, the majority argued that the healthcare providers may need to seek review of the CMMS decision under the Administrative Procedure Act instead of maintaining a supremacy clause action. The Court remanded the case so the parties could prepare new arguments based on the new circumstances. Chief Justice John G. Roberts Jr. wrote a dissent, stating that he would reverse because the health care providers no longer have a cause of action under the Supremacy Clause. Justices Antonin Scalia, Clarence Thomas, and Samuel A. Alito Jr. joined in the dissent.