## Facts

- Texas participated in Medicaid and was required to operate an Early and Periodic Screening, Diagnosis, and Treatment (EPSDT) program for children.
- Mothers of Medicaid-eligible children sued Texas state officials under 42 U.S.C. § 1983, seeking prospective injunctive relief for alleged noncompliance with federal EPSDT requirements.
- Claims against Texas state agencies were dismissed on Eleventh Amendment grounds; claims continued against state officials in their official capacities.
- The parties entered a federal consent decree, approved by the district court, setting detailed implementation and reporting requirements for the EPSDT program beyond the statute’s general terms.
- Plaintiffs later moved to enforce the decree, alleging noncompliance; the district court found decree violations and ordered further remedial steps.
- The Fifth Circuit reversed, holding the Eleventh Amendment barred enforcement absent a showing at the enforcement stage of an independent violation of the Medicaid Act.

## Issues

1. Whether the Eleventh Amendment bars a federal court from enforcing a consent decree against state officials that was entered to remedy alleged violations of federal law under Ex parte Young.
2. Whether enforcement is barred when the decree imposes detailed obligations not explicitly required by the federal statute and the enforcement motion does not reestablish a current statutory violation.

## Decision

- The Supreme Court reversed the Fifth Circuit and remanded.
- Enforcement of the consent decree against state officials did not violate the Eleventh Amendment.
- A federal court may enforce a consent decree that arises from a federal dispute and furthers federal statutory objectives, even if the decree’s terms are more specific than the statute and enforcement does not depend on proving a new statutory violation at that stage.
- If decree provisions become inappropriate or overly burdensome, the proper mechanism is modification of the decree, not a categorical immunity-based bar to enforcement.

## Legal Principles

- The Eleventh Amendment does not prevent federal courts from enforcing consent decrees entered against state officials to implement and secure compliance with federal law.
- A consent decree may include obligations that extend beyond a statute’s general language so long as the decree is consistent with federal law and furthers the law’s objectives.
- The Eleventh Amendment prohibition on federal courts ordering compliance with state law (as in Pennhurst) does not apply where the decree enforces federal-law-based obligations.
- District courts retain equitable authority to modify consent decrees when changed circumstances or federalism concerns justify adjustment.

## Conclusion

Federal courts may enforce federal consent decrees against state officials that implement federal statutory requirements without requiring a renewed finding of a current statutory violation at each enforcement stage, and any overbreadth concerns are addressed through modification rather than Eleventh Amendment immunity.


Frew ex rel. Frew v. Hawkins, 540 U.S. 431 (2004)