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2023 Supreme(US)(scotus) 21143

SUPREME COURT OF THE UNITED STATES
Ketanji Brown Jackson
Health and Hospital Corporation of Marion Cty. – Appellant
Versus
Talevski – Respondent



Syllabus

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.

SUPREME COURT OF THE UNITED STATES

Syllabus HEALTH AND HOSPITAL CORPORATION OF MARION COUNTY ET AL. v. TALEVSKI, AS PERSONAL REPRESENTATIVE OF THE ESTATE OF TALEVSKI CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SEVENTH CIRCUIT

No. 21–806. Argued November 8, 2022—Decided June 8, 2023 After Gorgi Talevski’s move to a nursing home in 2016 proved problem- atic, Talevski (through his wife Ivanka) brought an action under 42 U. S. C. §1983 against a county-owned nursing home and its agents (col- lectively, HHC), claiming that HHC’s treatment of Talevski violated rights guaranteed him under the Federal Nursing Home Reform Act (FNHRA). The District Court granted HHC’s subsequent motion to dismiss Talevski’s complaint, reasoning that no plaintiff can enforce provisions of the FNHRA via §1983. The Seventh Circuit reversed, concluding that the rights referred to in two FNHRA provisions in- voked by Talevski—the right to be free from unnecessary chemical re- straints, see §1396r(c)(1)(A)(ii), and rights to be discharged or trans- ferred only when certain preconditions are met, see §1396r(c)— “unambiguously confer individually enforceable rights on nursing- home residents,” making those rights presumptively enforceable via §1983. 6 F. 4th 713, 720. The Seventh Circuit further found nothing in the FNHRA to indicate congressional intent to foreclose §1983 en- forcement. Held: The FNHRA provisions at issue unambiguously create §1983-en- forceable rights, and the Court discerns no incompatibility between private enforcement under §1983 and the remedial scheme that Con- gress devised. Pp. 5–23. (a) Section 1983 has, since the 1870s, provided an express cause of action to any person deprived (by someone acting under color of state law) of “any rights . . . secured by the Constitution and laws.” The Court has long refused to read §1983’s unmodified term “laws” to mean 2 HEALTH AND HOSPITAL CORPORATION OF MARION CTY. v. TALEVSKI Syllabus

only some of the laws. Maine v. Thiboutot, 448 U. S. 1, 6. Looking to history, HHC attempts to sow doubt about §1983’s textually unquali- fied sweep, and proffers a Spending Clause-based argument to narrow §1983’s meaning. But a fuller picture of the relevant history lends HHC no aid. The Court is unpersuaded by HHC’s argument that, because Con- gress seems to have enacted the FNHRA pursuant to the Spending Clause, Talevski cannot invoke §1983 to vindicate rights recognized by the FNHRA. HHC starts with the Court’s observation that federal leg- islation premised on the Spending Clause power is “much in the nature of a contract,” Pennhurst State School and Hospital v. Halderman, 451 U. S. 1, 17. From there, HHC argues that Spending Clause statutes may not be enforced via §1983 because contracts were not generally enforceable by third-party beneficiaries at when §1983 was enacted in the 1870s. The Court rejects HHC’s argument. First, while the Court has reasoned that Congress’s failure to displace firmly rooted common- law principles generally indicates that it incorporated those estab- lished principles into §1983, Wyatt v. Cole, 504 U. S. 158, 163–164, HHC’s key common-law plank here—that third-party beneficiaries could not sue to enforce contractual obligations during the relevant time—is, at a minimum, cont

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