California Association of Rura v. David Maxwell-Jolly

This case concerns a clash of competing interests: the mission of publicly-funded health clinics to provide a panoply of medical services to under-served communities on the one hand, and California’s persistent budget woes on the other. We must decide whether California legislation that eliminates coverage for certain healthcare services, including adult dental, podiatry, optometry and chiropractic services, conflicts with the Medicaid Act, 42 U.S.C. §§ 1396 , et seq., and is therefore invalid. We hold that Medicaid prohibits the limitations adopted by the California legislature and, accordingly, we reverse and remand.

I. Background

Title XIX of the Social Security Act, referred to as the Medicaid Act, is a cooperative federal-state program through which the federal government provides financial assistance to states so that they can furnish medical care to low-income individuals. Wilder v. Va. Hosp. Ass’n, 496 U.S. 498, 502 , 110 S.Ct. 2510 , 110 L.Ed.2d 455 (1990) (citing 42 U.S.C. § 1396 ), superseded on other grounds by statute; 42 C.F.R. § 430.0 . Medicaid is jointly financed by federal and state governments and administered by the states through state plans…