Connell

This case arises from a joint effort by the State of California and the Federal Bureau of Investigation (“FBI”) to investigate fraud in the State’s Medicaid/MediCal Program. Plaintiffs are providers of medical services to Medi-Cal recipients. The California Department of Health Services (“DHS”) instructed the Controller of the State of California (“Controller”) to withhold payments to Plaintiffs after receiving an audit report from the Controller and other information from the FBI that Plaintiffs may have submitted fraudulent payment requests. Plaintiffs, in three separate actions under 42 U.S.C. § 1983 , sought to enjoin DHS from utilizing the Controller’s audit and the FBI information to withhold payments. The district court, ruling on cross-motions for summary judgment, granted Plaintiffs the relief they requested. It enjoined DHS from utilizing the Controller’s audits to withhold payments to Plaintiffs. The district court concluded that: (1) by authorizing the Controller to conduct Medi-Cal provider audits, DHS improperly delegat *936 ed its discretionary authority to the Controller in violation of a requirement under the Medicaid Act 1 that a single state agency administer or…