## Facts

- Illinois participated in the federal foster-care reimbursement program under the Adoption Assistance and Child Welfare Act of 1980 and maintained an approved state plan containing the Act’s “reasonable efforts” language.
- Children in the custody of the Illinois Department of Children and Family Services (DCFS) sued state officials as a class, alleging DCFS failed to make the “reasonable efforts” required by 42 U.S.C. § 671(a)(15) to prevent removal from the home and to facilitate return.
- The alleged failures included delays in assigning caseworkers to children in state custody and delays in reassigning cases when caseworkers left or took leave.
- The plaintiffs sought declaratory and injunctive relief to compel compliance with § 671(a)(15).
- The district court denied dismissal, found both an implied right of action and enforceability under 42 U.S.C. § 1983, and entered an injunction prescribing timelines for caseworker assignment and reassignment.
- The Seventh Circuit affirmed, concluding § 671(a)(15) was enforceable via § 1983 and that the Act also supported an implied cause of action.

## Issues

1. Whether 42 U.S.C. § 671(a)(15) creates an individual federal right enforceable against state officials under 42 U.S.C. § 1983.
2. Whether the Adoption Assistance and Child Welfare Act implies a private right of action allowing beneficiaries to sue state officials directly for violations of § 671(a)(15).

## Decision

- The Supreme Court reversed the Seventh Circuit.
- The Court held that § 671(a)(15) does not create rights enforceable under § 1983.
- The Court held that the Act does not contain an implied private right of action to enforce § 671(a)(15).
- The Court reasoned that § 671(a)(15) is framed as a condition of an approved state plan for federal funding, directed to the State as funding recipient rather than conferring specific entitlements on individuals.
- The Court concluded the phrase “reasonable efforts” is too general and indeterminate to constitute a clear, judicially enforceable standard required for Spending Clause conditions to be privately enforced.
- The Court emphasized that Congress provided an administrative enforcement scheme through the Secretary of Health and Human Services, including withholding or reducing funds for noncompliance, indicating no congressional intent to authorize private litigation.

## Legal Principles

- A Spending Clause statute is enforceable under § 1983 only if Congress unambiguously confers an individual right; plan-based funding conditions directed to states generally do not suffice.
- Statutory language that is broad and indeterminate (such as a requirement of “reasonable efforts”) is unlikely to establish a specific, judicially enforceable individual right.
- Where Congress establishes an administrative compliance and funding-withdrawal mechanism, courts are reluctant to infer that Congress also intended private judicial enforcement.
- An implied private right of action requires evidence of congressional intent to create both a private right and a private remedy; absent such intent, courts will not infer one.

## Conclusion

The Supreme Court held that the Adoption Act’s “reasonable efforts” requirement is a state-plan condition enforceable through federal administrative oversight, not a privately enforceable entitlement, and therefore it supports neither a § 1983 action nor an implied private cause of action.


Suter v. Artist M., 503 U.S. 347 (1992)