The U.S. Supreme Court delivered a significant ruling on Thursday, June 26, 2025, allowing South Carolina to exclude Planned Parenthood clinics from its state Medicaid program. In a 6-3 decision along ideological lines, the conservative majority reversed lower court rulings that had previously blocked the state’s efforts to defund the reproductive healthcare provider. This decision has far-reaching implications for Planned Parenthood’s access to public funding and for Medicaid patients’ ability to choose their healthcare providers nationwide.
The case, Medina v. Planned Parenthood South Atlantic, centered on whether low-income Medicaid patients could sue under Section 1983 of the Civil Rights Act of 1871 to enforce their right to choose a qualified healthcare provider, as guaranteed by the 1965 Medicaid Act. South Carolina Governor Henry McMaster had issued an executive order in 2018 to remove Planned Parenthood South Atlantic from the state’s Medicaid provider list, arguing that taxpayer money should not subsidize abortion providers, even though federal law already prohibits Medicaid funds from being used for abortions, except in limited circumstances.
Writing for the majority, Justice Neil Gorsuch stated that Section 1983 permits private lawsuits for violations of federal spending-power statutes only in “atypical” situations where the provision “clear[ly]” and “unambiguous[ly]” confers an individual “right.” Gorsuch concluded that the Medicaid Act’s “free choice of provider” clause is not such a statute. He emphasized that the decision on how to weigh competing costs and benefits of private enforcement actions belongs to elected representatives, not unelected judges. The typical redress for such a violation, he noted, would be for the Secretary of Health and Human Services to withhold Medicaid funding from the state, not for an individual to sue.
The ruling was met with strong dissent from the Court’s liberal justices. Justice Ketanji Brown Jackson, joined by Justices Sonia Sotomayor and Elena Kagan, criticized the majority’s approach as a “narrow and ahistorical reading” of Section 1983. Jackson argued that the decision effectively allows South Carolina to “evade liability for violating the rights of its Medicaid recipients to choose their own doctors,” undermining a venerable provision designed to allow citizens to seek redress for civil rights violations.
Planned Parenthood South Atlantic, which operates two clinics in South Carolina (in Columbia and Charleston), has consistently maintained that the case is not about abortion but about access to essential general healthcare services. These services include contraception, cancer screenings, and pregnancy testing, which are crucial for hundreds of low-income patients in a state with a shortage of primary care providers. NPR reported that Planned Parenthood is the largest single provider of reproductive health services and abortions in the United States, serving over two million patients and performing 9.13 million discrete services, including 392,715 abortions, in its 2023 Annual Report. The organization receives approximately $530 million in government funding, largely through Medicaid reimbursements, which by law cannot be used for abortion services.
South Carolina Governor McMaster hailed the decision as a victory, stating, “Seven years ago, we took a stand to protect the sanctity of life and defend South Carolina’s authority and values — and today, we are finally victorious.” John Bursch, a lawyer for the conservative Christian group Alliance Defending Freedom, which represented South Carolina, echoed this sentiment, asserting that “States should be free to fund real, comprehensive care and exclude organizations like Planned Parenthood that profit off abortion.”
Conversely, Paige Johnson, president of Planned Parenthood South Atlantic, condemned the ruling as a “grave injustice that strikes at the very bedrock of American freedom and promises to send South Carolina deeper into a health care crisis.” The decision comes at a challenging time for Planned Parenthood, which is already facing financial difficulties and clinic closures nationwide. NBC News highlighted that this ruling could embolden other Republican-led states to pursue similar measures, further restricting access to Planned Parenthood services for Medicaid patients. The ruling also arrives in the wake of the Supreme Court’s 2022 decision to overturn Roe v. Wade, which has led to stricter abortion bans, including South Carolina’s current six-week ban.
