Supreme Court Invents New Rule to Target Planned Parenthood
The Supreme Court’s recent decision in *FS Credit Opportunities v. Saba Capital Master Fund* has further complicated understanding of the Court’s 2025 ruling in *Medina v. Planned Parenthood*. In *Medina*, the Court appeared to depart from established precedent regarding “implied causes of action,” the legal doctrine allowing individuals to sue to enforce statutory rights. The *FS Credit* decision, while addressing a different area of law, reaffirms the prior legal standard for implied causes of action, despite not citing *Medina* or explaining why the *Medina* ruling was handled differently. This lack of consistency suggests the Court may be manipulating legal rules to achieve politically preferred outcomes, particularly concerning abortion access, rather than applying established legal principles uniformly.
John Q. Hosedrinker