Medina v. Planned Parenthood

Congress Lets Planned Parenthood Medicaid Ban Expire

Planned Parenthood and other reproductive health clinics have regained access to Medicaid funding after a one-year provision defunding them expired and was not renewed by Congress. This marks a significant shift, allowing clinics to bill Medicaid for non-abortion related services, though the previous year’s lack of funding, totaling over $800 million annually for Planned Parenthood alone, resulted in severe consequences. These included the denial of essential services to tens of thousands of patients, the closure of nearly 30 health centers, many in rural or underserved areas, and an overall 25% decrease in Medicaid visits to Planned Parenthood. Despite this restoration, future funding remains uncertain, as states can still independently block Medicaid funds, and anti-abortion advocates are pushing for the defunding ban to be reinstated.

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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.

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