Health & Hospital Corporation of Marion County v. Talevski

The family of Gorgi Talevski brought a lawsuit against his state-run nursing facility, claiming that the facility had violated his rights under the Federal Nursing Home Reform Act (FNHRA). The defendants claim that legislation enacted under Congress’s Spending Clause power, such as FNHRA, does not give rise to privately enforceable rights under 42 U.S.C. § 1983, and thus individuals cannot sue state actors for violation of these rights. 

Juvenile Law Center joined the National Center for Youth Law and fifteen other advocacy organizations in filing an amicus brief in the United States Supreme Court, arguing that adopting the defendants’ interpretation would “cut an essential, firmly established lifeline for vulnerable Americans,” including the millions of children who depend on federally funded, state-administered services. The brief argued that the question of whether a federal right is enforceable under Section 1983 cannot be faithfully resolved by a bright-line rule barring all private enforcement of Spending Clause legislation, and that such a rule would exacerbate the harm that individuals suffer when their federal rights are violated by state actors. 

In a win for youth and other vulnerable Americans, the United States Supreme Court held that the “FNHRA provisions at issue unambiguously create § 1983-enforceable rights.”  This decision preserves long-standing precedent that beneficiaries of certain federal spending programs have the right to sue when states violate their rights under those programs.