## Facts

- Missouri limited Medicaid reimbursement for abortions to those deemed “medically indicated.”
- Two Missouri physicians who provided abortions to Medicaid-eligible women sought declaratory and injunctive relief, alleging the restriction unlawfully burdened indigent women’s abortion decisions.
- The physicians alleged the state had refused all Medicaid reimbursement requests connected to abortions covered by the restriction and that they expected continued denials as they continued providing services.
- A three-judge federal district court dismissed the claim for lack of standing.
- The Eighth Circuit reversed, found standing, and held the restriction unconstitutional under the Equal Protection Clause.
- The state official had filed only a pre-answer motion to dismiss and had not presented a merits defense or developed a factual record.

## Issues

1. Whether the physicians alleged a sufficient Article III injury in fact based on denied and expected Medicaid reimbursements.
2. Whether the physicians could, as a prudential matter, assert the constitutional rights of their patients rather than only their own interests.
3. Whether the court of appeals properly reached and decided the constitutionality of the Medicaid restriction without giving the state an opportunity to litigate the merits.

## Decision

- The Court held the physicians satisfied Article III standing because denial of reimbursement alleged a concrete economic injury and a likelihood of future injury.
- A plurality concluded the physicians could assert patients’ rights because the physician–patient relationship was close and patients faced practical impediments to suing directly (privacy concerns and pregnancy-related mootness).
- The Court reversed the judgment declaring the statute unconstitutional and remanded because the court of appeals should not have decided the merits on a record limited to a pre-answer standing dismissal.

## Legal Principles

- Economic harm from denial of government payment can constitute injury in fact sufficient for Article III standing when the plaintiff alleges actual and likely future denials.
- Third-party standing may be permitted when (1) the litigant has a close relationship with the right-holder and (2) there exists a genuine impediment to the right-holder’s ability to sue.
- Appellate courts should not resolve constitutional merits questions when the opposing party has not been allowed to answer, present evidence, or advance legal defenses on a developed record.

## Conclusion

The Court recognized physicians’ standing to challenge a Medicaid abortion-funding restriction, including (per a plurality) to assert patients’ constitutional rights, but required remand because the merits were decided without a fair opportunity for the state to litigate and develop the record.


Singleton v. Wulff, 428 U.S. 106 (1976)