- Court: United States Supreme Court
- Area(s) of Law: Civil Law
- Date Filed: June 8, 2023
- Case #: No. 21–806
- Judge(s)/Court Below: Jackson, J., for the Court; Roberts, C.J.; Thomas, J.; Alito, J.; Sotomayor, J.; Kagan, J.; Gorsuch, J.; Kavanaugh, J.; Barrett, J.
- Full Text Opinion
Respondent Talevski filed a lawsuit against Appellants for violating two provisions of the Nursing Home Reform Act (NHRA). Respondent relied on 42 U.S.C § 1983, which provides a civil remedy for the deprivation of rights. The Seventh Circuit found that the NHRA conferred rights on the Respondent, and that violation of those rights gave rise to a claim. Appellant assigned error.
Appellant argued that because the NHRA was created via Congress’ spending power, it should be viewed as a contract between the Federal and State governments and that any other party is a third party beneficiary. Pennhurst State School and Hospital v. Halderman, 451 U. S. 1, 17 (1981). Because contract law did not allow a third party beneficiary to sue a breaching party at the time §1983 was passed, civil claims should be barred.
The Court found that any law created by Congress which confers rights to individuals may give rise to a cause of action. Only if a “private [...] action under §1983 would thwart any enforcement mechanism [...]” would a cause of action be barred. Gonzaga Univ. v. Doe, 536 U. S., 273, 284 (2002). The Court applied the Gonzaga test to find that the NHRA was “phrased in terms that of the persons benefited” and contained “rights-creating” language, and thus created a cause of action.
AFFIRMED.