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Frew ex rel. Frew v. Hawkins

United States Supreme Court
540 U.S. 431 (2004)

Written by Sean Carroll, JD

Facts

To receive Medicaid funds, states were required to administer their state programs in certain ways, including establishing an Early and Periodic Screening, Diagnosis, and Treatment (EPSDT) program. Federal law did not provide specifics as to how a state was required to design and implement an EPSDT program. Frew and other mothers (plaintiffs) of children eligible for Texas’s EPSDT program sued the State of Texas (defendant), alleging that the state’s EPSDT program was not in compliance with federal law. The plaintiffs and the state entered into a consent decree to resolve the lawsuit. The consent decree provided specifically how Texas was to implement and administer its EPSDT program. The district court approved the consent decree. The plaintiffs moved to enforce the consent decree. The state argued that the Eleventh Amendment precluded enforcement of the consent decree. The district court rejected this contention and held that the state had violated the consent decree. The United States Court of Appeals for the Fifth Circuit reversed on Eleventh-Amendment grounds. The United States Supreme Court granted certiorari.

Rule of Law

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Issue

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Holding and Reasoning (Kennedy, J.)

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A "yes" or "no" answer to the question framed in the issue section;
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The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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