## Facts

- Medicaid-eligible children and advocacy organizations alleged Michigan’s Medicaid administration systematically failed to provide required EPSDT services for individuals under age 21.
- Plaintiffs sought declaratory and prospective injunctive relief against Michigan health officials in their official capacities, including appointment of a special master.
- The complaint relied principally on EPSDT-related duties in the Medicaid Act, including informing and outreach requirements and ensuring screening, diagnostic, and treatment services.
- The district court dismissed, reasoning that Medicaid functioned only as a contract between Michigan and the federal government, that the Eleventh Amendment barred the suit because the state was the real party in interest, and that Spending Clause statutes did not create rights enforceable under 42 U.S.C. § 1983.
- Plaintiffs appealed; the United States intervened in the court of appeals on issues concerning enforceability of Spending Clause legislation against state officials for prospective relief.

## Issues

1. Whether Medicaid is enforceable federal law under the Supremacy Clause rather than a mere contract between a participating state and the federal government.
2. Whether the Eleventh Amendment bars a § 1983 action seeking prospective injunctive relief against state officials for ongoing noncompliance with Medicaid requirements.
3. Whether specific Medicaid Act provisions governing EPSDT create individual rights enforceable by Medicaid recipients under 42 U.S.C. § 1983.

## Decision

- The Sixth Circuit reversed the dismissal and remanded for further proceedings.
- The court held Medicaid is federal statutory law enacted under the Spending Clause and operates as the “supreme Law of the Land” for participating states.
- The court held the Eleventh Amendment did not bar the suit because plaintiffs sought prospective injunctive relief against state officials for alleged ongoing violations of federal law under Ex parte Young.
- The court held at least some EPSDT-related Medicaid provisions are enforceable through § 1983 because they confer specific, mandatory entitlements on identified beneficiaries rather than stating generalized policy goals.
- The court did not decide whether Michigan in fact violated EPSDT requirements; it held the pleadings stated potentially enforceable claims.

## Legal Principles

- Spending Clause statutes, including Medicaid, are federal law capable of judicial enforcement when a state elects to participate and accepts federal conditions.
- Under Ex parte Young, state sovereign immunity does not bar suits against state officials in their official capacities seeking prospective equitable relief to end ongoing violations of federal law.
- Medicaid provisions may be enforced via 42 U.S.C. § 1983 when they are framed in mandatory terms and confer specific benefits or entitlements on a defined class of persons.
- Alleged failures to provide and arrange EPSDT screening, diagnostic, and treatment services, and to inform eligible recipients about those services, can state claims premised on enforceable statutory rights, subject to further litigation on the merits.

## Conclusion

The Sixth Circuit allowed Medicaid recipients and advocacy plaintiffs to pursue prospective injunctive relief against Michigan officials for alleged EPSDT noncompliance, rejecting the view that Medicaid is merely contractual, applying Ex parte Young to avoid Eleventh Amendment immunity, and recognizing that certain EPSDT duties can be enforced under § 1983.


Westside Mothers v. Haveman, 289 F.3d 852 (6th Cir. 2002)