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Westside Mothers v. Haveman

United States Court of Appeals for the Sixth Circuit
289 F.3d 852 (2002)


Facts

The federal Medicaid program provides health care financial assistance to low-income residents of a participating state. States participating in the Medicaid program are required to comply with the Medicaid Act (MA) as well as the regulations promulgated to carry out the MA’s purpose. One such federal regulation requires participating states to provide “early and periodic screening, diagnostic, and treatment services” for eligible individuals under 21-years of age. Westside Mothers (plaintiff) sued James Haveman, director of the Michigan Department of Community Health (defendant) and others under 42 U.S.C. § 1983, alleging that Michigan had refused or failed to provide screening and treatment services. Section 1983 creates a private cause of action against any person who deprives an individual of “any right, privileges, or immunities secured by the Constitution and law” of the United States. The district court granted Haveman’s motion to dismiss, holding that (1) Medicaid was only a contract between a state and the federal government, (2) that spending-power programs like Medicaid were not the supreme law of the land, (3) that the court lacked jurisdiction over the matter because Michigan enjoyed sovereign immunity, and (4) Section 1983 did not create a private cause of action for Westside Mothers. Westside Mothers appealed to the court of appeals.

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Holding and Reasoning (Merritt, J.)

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