Armstrong v. Exceptional Child Center, Inc.

Whether Medicaid providers have a right to enforce 42 U.S.C. § 1396a(a)(30)(A) under the Supremacy Clause where Congress did not give that right.

Respondents filed suit against appellants for injunctive relief to prevent the enforcement or implementation of legislation. Section 30(A) of the Medicaid Act requires the reimbursement rates paid to medical providers to "bear reasonable relationship" with their costs. If there is no reasonable relationship, there must be more justification than purely budgetary reasons. Respondents had conducted cost studies each year between 2006 and 2009 and recommended substantial increases in their rates based on the studies. Appellants refused to increase the rates because the State did not have enough funds.

Appellants appealed a District Court grant of summary judgment to Respondents and the Ninth Circuit affirmed the grant of summary judgment, holding that the Supremacy Clause provides a private right of action, even though Congress did not provide for one in the statute. The Supreme Court granted certiorari limited to question one of the petition.

Appellants argue that the Ninth Circuit disregarded the Supreme Court's cases that limit a private right of action unless Congress has created one.