The Supreme Court of the United States announced decisions in three cases today:
Douglas v. Independent Living Center of Southern California, Inc., No. 09-958: The Court granted certiorari to decide whether Medicaid providers and recipients could maintain a cause of action under the Supremacy Clause to enforce a federal Medicaid law that, in their view, preempted state Medicaid statutes that reduced payments to providers. After cert was granted, the federal agency in charge of administering Medicaid approved the state statutes as consistent with the federal law. In light of this changed circumstance, the Court today stated that the question has become whether, once the agency has approved the state statutes, groups of Medicaid providers and beneficiaries may still maintain a Supremacy Clause action asserting that the state statutes are inconsistent with the federal Medicaid law. Accordingly, the Court vacated the Ninth Circuit’s judgments and remanded for the parties to argue the new question there in the first instance.
The Court’s opinion is available
here.
PPL Montana, LLC v. Montana, No. 10-218: Three rivers (the Missouri, the Madison, and the Clark Fork) flow through Montana and then beyond its borders. In a dispute with a power company, Montana claimed ownership of the riverbeds in certain locations and sought rent, which the power company had been paying to the United States. The question turned on whether discrete, identifiable segments of these rivers were “nonnavigable,” as federal law defines that concept for purposes of determining whether the State acquired title to the riverbeds underlying those segments when the State entered the Union in 1889; if they were nonnavigable, then the State did not acquire title. The Montana Supreme Court determined that the river segments were navigable at statehood and that the State thus owned the riverbeds. The Court today reversed the state supreme court, holding it had applied incorrect tests to determine historic navigability, and remanded for further proceedings.
The Court’s opinion is available
here.
Messerschmidt v. Millender, No. 10-704: In connection with an investigation of a known gang member for shooting at his ex-girlfriend with a pistol-gripped sawed-off shotgun, police officers searched respondents’ home pursuant to a warrant which authorized a search for all guns and gang-related material. Respondents later brought an action seeking to hold the officers personally liable under 42 U. S. C. §1983, alleging that the search violated their Fourth Amendment rights because there was not sufficient probable cause to believe the items sought were evidence of a crime. In particular, respondents argued that there was no basis to search for all guns simply because the suspect owned and had used a sawed-off shotgun, and no reason to search for gang material because the shooting at the ex-girlfriend for “call[ing] the cops” was solely a domestic dispute. The Ninth Circuit held that the warrant was so obviously invalid that the officers had no immunity from the §1983 suit. Today the Court reversed and held the officers are entitled to qualified immunity.
The Court’s opinion is available
here.