Health and Hospital Corporation of Marion County v. Talevski

Health and Hospital Corporation of Marion County v. Talevski
Argued November 8, 2022
Decided June 8, 2023
Full case nameHealth and Hospital Corporation of Marion County, et al. v. Ivanka Talevski, Personal Representative of the Estate of Gorgi Talevski, Deceased
Docket no.21-806
Citations599 U.S. 166 (more)
ArgumentOral argument
Opinion announcementOpinion announcement
Questions presented
(1) Whether, in light of compelling historical evidence to the contrary, the Supreme Court should reexamine its holding that Spending Clause legislation gives rise to privately enforceable rights under 42 U.S.C. § 1983; and
(2) Whether, assuming Spending Clause statutes ever give rise to private rights enforceable via Section 1983, the Federal Nursing Home Amendments Act of 1987's transfer and medication rules do so.
Holding
The provisions of the Federal Nursing Home Reform Act at issue unambiguously create rights enforceable under 42 U.S.C. §1983, and private enforcement under §1983 is compatible with the FNHRA’s remedial scheme. A plaintiff can file a federal civil rights claim because of violation of the Federal Nursing Home Reform Act.[1]
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Samuel Alito
Sonia Sotomayor · Elena Kagan
Neil Gorsuch · Brett Kavanaugh
Amy Coney Barrett · Ketanji Brown Jackson
Case opinions
MajorityJackson, joined by Roberts, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett
ConcurrenceGorsuch
ConcurrenceBarrett, joined by Roberts
DissentThomas
DissentAlito, joined by Thomas

Health and Hospital Corporation of Marion County v. Talevski, 599 U.S. 166 (2023), was a United States Supreme Court case related to private enforcement of Spending Clause statutes. It relates to whether third parties can initiate lawsuits against public institutions for violations of Congressional spending bills under claims of Section 1983, which was established to protect individual rights from constitutional violations from public institutions.