FREW EX REL. FREW V. HAWKINS
540 U.S. 431 (2004)
NATURE OF THE CASE: This was a dispute over whether enforcement of a consent decree
against state officials involving federal Medicaid programs was enforceable against state
officials in the federal court the decrees was entered into.
FACTS: Medicaid is a cooperative federal-state program that provides federal funding for
state medical services to the poor. State participation is voluntary; but once a State
elects to join the program, it must administer a state plan that meets federal requirements.
Each state must have an EPSDT. The EPSDT provisions of the Medicaid statute require
participating States to provide various medical services to eligible children, and to
provide notice of the services. Frew (Ps) mothers of children eligible for EPSDT services
filed a civil action pursuant under 42 U. S. C. 1983, seeking injunctive relief against
various Texas state officials. Ps alleged that the Texas program did not satisfy the
requirements of federal law. Two Texas state agencies named in the suit moved to dismiss the
claims against them on Eleventh Amendment grounds. The petitioners did not object, and the
District Court dismissed the state agencies as parties. The state officials remained in the
suit, and the District Court certified a class consisting of children in Texas entitled to
EPSDT services, a class of more than 1 million persons. Following extensive settlement
negotiations, Ps and the state officials agreed to resolve the suit by entering into a
consent decree. The District Court conducted a fairness hearing, approved the consent
decree, and entered it in 1996. The decree is a detailed document about 80 pages long that
orders a comprehensive plan for implementing the federal statute. The consent decree
requires the state officials to implement many specific procedures. Two years after the
consent decree was entered, Ps filed a motion to enforce it in the District Court; The state
officials (Ds) had not complied with the decree in various respects. Ds denied the
allegations and maintained that the Eleventh Amendment rendered the decree unenforceable
even if they were in noncompliance. The District Court issued a detailed opinion concluding
that certain provisions of the consent decree had been violated. Ds filed an interlocutory
appeal, and the Court of Appeals for the Fifth Circuit reversed. It held that the Eleventh
Amendment prevented enforcement of the decree unless the violation of the consent decree was
also a statutory violation of the Medicaid Act that imposed a clear and binding obligation
on the State. The Court of Appeals concluded that because Ps had not established a violation
of federal law, the District Court lacked jurisdiction to remedy the consent decree
violations. Other Circuits have reached a contrary result, holding that the Eleventh
Amendment does not bar enforcement of consent decrees in like circumstances. The Supreme
Court granted certiorari.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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