
The Supreme Court is currently deliberating a pivotal case that could determine whether 72 million Americans who rely on Medicaid can choose their healthcare providers and enforce this right through legal action. This case, Medina v. Planned Parenthood South Atlantic, has far-reaching implications for healthcare access across the nation.
The Origins of the Case
The legal battle began during President Trump’s first term when South Carolina Governor Henry McMaster issued an executive order in July 2018 barring healthcare providers that offer abortions from receiving Medicaid reimbursements. This directly affected Planned Parenthood, which operates two clinics in South Carolina where Medicaid patients received various healthcare services including physical exams, cancer screenings, and contraception.
Julie Edwards, a Medicaid enrollee who received care at a Planned Parenthood clinic in Columbia, South Carolina, found herself unable to continue receiving services there. Along with Planned Parenthood, she sued South Carolina, arguing that the state violated the federal Medicare and Medicaid Act by restricting her choice of provider.
The Legal Foundation
At the heart of this case is the “free-choice-of-provider” requirement that Congress added to Medicaid in 1967. This provision states that Medicaid recipients “may obtain such assistance from any institution, agency, community pharmacy, or person, qualified to perform the service or services required.”
The case hinges on whether Section 1983, a civil rights statute enacted in 1871, provides Medicaid beneficiaries the right to sue when their federal rights are violated. During oral arguments on April 2, 2025, Justice Elena Kagan emphasized, “There’s a right, and the right is the right to choose your doctor.”
Competing Arguments
John J. Bursch, representing South Carolina’s Director of Health and Human Services Eunice Medina, contended that the statute’s language lacks what he called a “rights-creating pedigree.” The Trump administration supported this position.
Conversely, Planned Parenthood’s lawyer Nicole A. Saharsky argued that the creation of a right shouldn’t depend on “some kind of magic words test.” She emphasized that Congress intended to protect “an intensely personal right” to choose one’s doctor, especially when facing significant health challenges.
Beyond Abortion Services
While Governor McMaster justified removing Planned Parenthood from the state’s Medicaid program to prevent indirect subsidization of abortions, it’s worth noting that only 3% of Planned Parenthood’s nationwide services are abortion-related. The organization primarily provides STD testing and serves over 2 million predominantly low-income patients annually.
Through the Hyde Amendment, Medicaid already prohibits reimbursement for abortions except in cases involving risk to the mother’s life or pregnancies resulting from rape or incest.
Potential Nationwide Impact
The Supreme Court’s decision could extend far beyond South Carolina. Arkansas, Missouri, and Texas have already excluded Planned Parenthood from Medicaid reimbursements for all services. If the Court rules in South Carolina’s favor, other states might follow suit.
Furthermore, the ruling could empower states to exclude providers based on various characteristics, such as union membership among employees or provision of gender-affirming care, significantly limiting patient choices.
Judicial Precedent
Lower courts have consistently upheld Edwards’ right to obtain Medicaid-funded care at Planned Parenthood, and the Supreme Court has long recognized Section 1983’s protection of individuals’ ability to sue when federal statutory rights are violated. In 2023, the Court found such a right under the Medicaid Nursing Home Reform Act.
What Happens Next
Regardless of the Supreme Court’s decision, the controversy will likely continue. If the Court rules in Edwards’ favor, lower courts must still determine whether South Carolina appropriately classified Planned Parenthood as an “unqualified provider.” If South Carolina prevails, Planned Parenthood could still challenge the state’s “unqualified” designation through other legal avenues.
The outcome of this case will significantly impact healthcare access for millions of Americans who depend on Medicaid for their medical needs, potentially reshaping the relationship between federal healthcare programs and state administration.
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