## Facts

- Gorgi Talevski, a nursing-home resident with dementia, was admitted in 2016 to Valparaiso Care and Rehabilitation, a facility operated by a county-owned public health corporation and participating in Medicaid.
- His family observed a sharp decline and later alleged the facility used psychotropic drugs as an unnecessary “chemical restraint.”
- After the family complained to state regulators, the facility repeatedly transferred him to a distant hospital without family notice and ultimately refused to readmit him.
- The facility involuntarily discharged him to a far-away memory-care facility.
- A state administrative law judge ruled the discharge improper, but the facility did not readmit him.
- His wife, as representative, sued under 42 U.S.C. § 1983, alleging violations of rights guaranteed by the Federal Nursing Home Reform Act (FNHRA), including freedom from unnecessary chemical restraints and statutory limits/procedures governing transfer and discharge.

## Issues

1. Whether legislation enacted under the Spending Clause can create federal rights enforceable by individuals through 42 U.S.C. § 1983.
2. Whether FNHRA’s chemical-restraint and transfer/discharge provisions unambiguously confer individual rights enforceable under § 1983, and whether FNHRA’s enforcement scheme forecloses § 1983 suits.

## Decision

- The Supreme Court affirmed the court of appeals (7–2).
- Spending Clause statutes are not categorically exempt from § 1983; such statutes may create individual rights enforceable under § 1983.
- The FNHRA provisions at issue unambiguously create rights for nursing-home residents enforceable under § 1983.
- FNHRA’s administrative and regulatory enforcement mechanisms do not reflect congressional intent to displace § 1983 enforcement.

## Legal Principles

- Section 1983 provides a cause of action for deprivation, under color of state law, of “rights, privileges, or immunities secured by the Constitution and laws,” and this text extends to statutory rights, including those arising in Spending Clause programs.
- A statutory provision creates a § 1983-enforceable right when it is phrased in terms of the persons benefited and uses rights-creating, individual-focused language with a clear focus on the protected class.
- Once a provision unambiguously confers an individual right, it is presumptively enforceable under § 1983 unless Congress expressly or impliedly forecloses § 1983 by creating a remedial scheme that is sufficiently comprehensive or incompatible with § 1983.
- FNHRA’s “residents’ rights” provisions—including protections against unnecessary chemical restraints and limits/procedures on transfer and discharge—use rights-creating language directed to residents, not merely funding conditions directed to governments or regulated entities.
- Agency oversight and facility-focused sanctions, without a clear indication of exclusivity, generally do not bar § 1983 suits seeking to vindicate individual statutory rights.

## Conclusion

The Court held that Spending Clause statutes may confer individual rights enforceable under § 1983 and that FNHRA’s protections against unnecessary chemical restraints and improper transfer/discharge create enforceable rights not displaced by FNHRA’s administrative enforcement regime.


Health & Hosp. Corp. of Marion Cnty. v. Talevski, 599 U.S. 166 (2023)