“Today’s decision is likely to result in tangible harm to real people… it will deprive Medicaid recipients… of their only meaningful way of enforcing a right that Congress has expressly granted to them. And, more concretely, it will strip [them]... of a deeply personal freedom: the ‘ability to decide who treats us at our most vulnerable’.”

The Case

Planned Parenthood South Atlantic provides a wide variety of services to patients in South Carolina, both Medicaid and non-Medicaid. These services include abortion. In July 2018, the Governor of South Carolina banned sending any Medicaid funding to clinics that offer abortions. Under this, Planned Parenthood would no longer be able to participate in South Carolina’s Medicaid program. 

In response, Planned Parenthood South Atlantic and Medicaid patient Julie Edwards filed a lawsuit, arguing that the decision made by South Carolina’s government violated the Medicaid Act’s “any qualified provider” provision. Edwards claimed that since she preferred to receive gynecological care from Planned Parenthood and relies on Medicaid to afford the service, she should have the support she alleges is guaranteed by the federal Medicaid statute.

Initial Ruling

In a controversial legal development, several states began passing laws and administrative rules seeking to disqualify health clinics that provide abortion and preventative care services from Medicaid funding. While many of these clinics still provided other non-abortion-related care, such as cancer screening, vaccines, and family planning, some laws prevented them from seeking external funding. These measures were primarily aimed at organizations such as Planned Parenthood.

The initial legal challenges were brought by advocacy groups and healthcare providers, arguing that such exclusions violate federal Medicaid law, which guarantees patients the right to choose among qualified providers. The reception amongst this was fragmented and split. Some lower courts ruled in favor of clinics, citing federal preemption and patient choice, while others sided with the states, asserting that states have the authority to determine Medicaid provider qualifications beyond federal minimums.

SCOTUS Ruling

On July 1, 2025, the Supreme Court of the United States issued a landmark decision siding with states in a major ruling that reshapes the landscape of reproductive healthcare access in America. In a narrow 5–4 decision in Medina v. Planned Parenthood South Atlantic, the Court upheld the authority of states to exclude healthcare providers from their Medicaid programs if those providers are affiliated with abortion services, even when the excluded services are wholly unrelated to abortion and are not funded by federal dollars.

Justice Neil Gorsuch, writer of the majority opinion, claimed that if Congress wants to clarify that patients have an enforceable right to choose their doctor, lawmakers should re-pass Medicaid legislation to include that exact verbiage, because, currently, “that is not the law we have.”

The ruling also settled a long-disputed legal question: Whether individual Medicaid recipients have the right to sue under Section 1983 to challenge a state’s decision to bar providers. The Court ruled they do not, closing the door to future legal challenges from patients who argue their right to choose qualified providers is being violated. This portion of the ruling represents a significant rollback of legal recourse for low-income patients who rely on Medicaid for essential healthcare and had previously challenged such exclusions in federal court.

Healthcare advocates and civil rights organizations swiftly condemned the ruling. Planned Parenthood Federation of America called it “a devastating blow to healthcare equity,” warning that it could lead to widespread clinic closures and leave tens of thousands of patients without access to basic services such as contraception, cancer screenings, and STD testing.

By upholding these state powers, the Supreme Court has effectively created a legal roadmap for other conservative-led states to follow suit, likely accelerating a new wave of Medicaid defunding efforts nationwide. 

Future Implications

Currently, 20% of South Carolinians (over 1 million) receive health care services through the Medicaid program, with 5% of those recipients seeking sexual and reproductive health care services from Planned Parenthood in 2025.

While the effects of this ruling will first impact the citizens of South Carolina, 18 states, including Texas, Arkansas, and Missouri, who have already attempted to cut Planned Parenthood medicaid funding, backed South Carolina in this case. 

This decision will deepen the healthcare accessibility divide between states. In progressive states, providers offering abortion services may continue to receive Medicaid funding for non-abortion services. But in states where abortion is heavily restricted or banned, this ruling allows policymakers to economically isolate abortion providers by targeting their financial viability. Patients in these areas will face diminished options for comprehensive care.

Critics also worry that the ruling could set a precedent for broader exclusions beyond reproductive healthcare. If states can disqualify providers based on political or moral objections rather than professional qualifications, similar arguments could be extended to clinics that offer gender-affirming care, HIV prevention services, or even mental health support tied to controversial social issues. The door is now open for Medicaid, a program originally designed to expand access to care, to be used to set a precedent of ideological enforcement.

Perhaps the most sweeping implication is the Court’s finding that individual Medicaid recipients lack standing to sue under Section 1983. This removes a key mechanism by which patients previously challenged provider exclusions in federal court. Without that private right of action, clinics and patients will face enormous hurdles in resisting politically motivated defunding efforts, while state health departments will have greater autonomy with less judicial oversight.