## Facts

- Melvinteen Daniels lived at John J. Kane Regional Center–Glen Hazel, a county-operated skilled nursing and rehabilitation facility participating in Medicaid.
- Daniels’s estate alleged the facility failed to provide adequate care, causing Daniels to develop pressure ulcers, malnutrition, sepsis, and death.
- The estate sued under 42 U.S.C. § 1983, asserting wrongful-death and survival claims based on alleged violations of resident protections in the Federal Nursing Home Reform Amendments (FNHRA), 42 U.S.C. § 1396r.
- The asserted statutory protections included care and services to maintain the “highest practicable” well-being, limits on unnecessary physical or chemical restraints, and protections against abuse and neglect.
- The district court dismissed under Rule 12(b)(6), holding FNHRA did not create rights enforceable through § 1983 and instead set conditions for Medicaid participation.

## Issues

1. Whether provisions of FNHRA, 42 U.S.C. § 1396r, unambiguously confer individual federal rights on nursing home residents enforceable under 42 U.S.C. § 1983.
2. Whether the asserted FNHRA protections are too vague for judicial enforcement.
3. Whether Congress foreclosed § 1983 enforcement by providing an exclusive, comprehensive remedial scheme within FNHRA.

## Decision

- The Third Circuit reversed the dismissal and remanded.
- The court held that an action may be brought under § 1983 to challenge alleged violations of FNHRA-based resident rights by a county-operated, Medicaid-participating nursing facility.
- The court concluded the cited FNHRA provisions contain rights-creating language focused on residents rather than solely on regulated entities.
- The court held the asserted protections were sufficiently definite for courts to enforce.
- The court held FNHRA’s regulatory enforcement mechanisms did not show congressional intent to displace § 1983.

## Legal Principles

- A Spending Clause statute supports § 1983 enforcement when it contains unambiguous rights-creating language, the right is judicially manageable, and Congress has not displaced § 1983 with an incompatible, comprehensive remedial scheme.
- FNHRA provisions that speak in terms of “residents” and impose concrete duties on facilities can create individually enforceable federal rights under § 1983.
- FNHRA’s inspection, certification, and funding-related sanctions primarily regulate facility participation and do not, by themselves, provide an exclusive remedial path for individual residents sufficient to bar § 1983.

## Conclusion

The Third Circuit held that certain FNHRA resident protections confer individual federal rights enforceable under § 1983 and that FNHRA’s administrative and funding-based enforcement measures do not foreclose § 1983 suits against a county-run, Medicaid-participating nursing facility, requiring reversal of the complaint’s dismissal and remand for further proceedings.


Grammer v. John J. Kane Reg'l Ctrs.-Glen Hazel, 570 F.3d 520 (3d Cir. 2009)