Armstrong v. Exceptional Child Center, Inc. (14-15)

argument 14-15

Armstrong v. Exceptional Child Center, Inc.

Supreme Court of the United States 1h 1m 5 speakers 8 chapters transcribed 6 days ago official recording ↗

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What is the main topic discussed in this episode?

John G. Roberts 0:02

We'll hear argument first this morning in case fourteen fifteen Armstrong versus the exceptional child centre. Mr Withthrow?

Paul R. Withrow 0:13

Thank you, Mr Chief Justice, and may it please the court. Respondents have no rights under Section thirty A, and so they have no privately enforceable right of action to enforce that statute under Section nineteen eighty three or under an implied right of action.

What is the Supreme Court’s initial stance on whether respondents have any rights under §30A?

Paul R. Withrow 0:28

The supremacy clause does not provide an alternative freestanding right of action to enforce Section thirty A either. This case is distinguishable from the cases where this court has invalidated state or local law under the Supremacy Clause.

How does the Court distinguish this case from traditional Supremacy‑Clause preemption cases?

Paul R. Withrow 0:43

In fact, this is not a preemption case at all. It is an action to enforce statute, and it is foreclosed by Sandoval, Gonzaga University, and Astra. Preemption solves the problem of two separate sovereigns regulating independently in the same territory. The supremacy clause resolves the conflict That arises when state law regulates a plaintiff in a manner that federal law protects against.

Why do the parties argue that the dispute is an enforcement action rather than a preemption claim?

Elena Kagan 1:13

if this is unlike those other cases. Um where we've invoked the supremacy clause. What's the basis for those cases?

Paul R. Withrow 1:24

The the basis for those cases is that there there would have been federal law that allowed plaintiff's conduct and then state law that interfered with that conduct, that it was allowed by federal law, and thus the supremacy clause. uh resolved the the conflict and provided.

Elena Kagan 1:41

I am not sure I understand your answer. That's the claim here. That there's a federal law. that is contrary to the state law. And I don't know why you can't look at this as an enforcement action. The state law won't permit. these individuals. to charge an amount greater than where they're willing to pay. So if these doctors or providers Wanted to charge more. they would be in violation of state law. and would have an enforcement action against them.

What is the Idaho waiver methodology for setting Medicaid rates and how does it affect the parties?

Elena Kagan 2:18

So I mean I don't I don't actually see this enforcement um disinforcement argument that you're making.

Paul R. Withrow 2:26

I have two responses to that, Justice Sotomayor. The first is that under Idaho's uh scheme that there would not arise a situation where providers are charging patients more than the state allows. The way that it works in Idaho, particularly with respect to this waiver program, is that the providers provide the service to the beneficiary The providers then bill the state and the state reimburses them. And both under federal regulations and state regulations, the providers come into the program and agree to take as payment in full the amount the lesser of the amount of their customary charges or the state set rates. And so we would not have a situation where We they they would be charging, resorting to self help and charging more than the uh than the other thing.

Elena Kagan 3:18

You would pay it.

Paul R. Withrow 3:20

That that's correct, Your Honor. We we wouldn't pay it. They they in fact send us bills all the time with their customary charge and and we pay them the state rate. We still

Anthony M. Kennedy 3:29

but what if they just Asked the uh the the patient herself to try to pay a supplemental rate. And then you would have come in and you would say, You know, you can't do that. And that would be balance billing, which is also

Paul R. Withrow 3:42

not allowed under f st state or federal law.

Anthony M. Kennedy 3:44

Yes, it's not allowed. That's right. But that's why you would bring an enforcement action against such a supplemental bill.

Paul R. Withrow 3:50

And their defense would not be they wouldn't have a valid defense that our rates are too low in violation of the Medicaid Act because they don't have a right to a specific rate or a process or anything else under Section thirty A. And so they couldn't raise if we if under that situation we were to go after them for violating. That would

Anthony M. Kennedy 4:07

be a merits question. I mean they would make that exact claim. They would say The rates are too low, the rates violate federal law, we're entitled to a higher rate.

Paul R. Withrow 4:18

And and that that might go to the to the merits there, but what we would say is that you look at the statute first and the statute doesn't entitle them to anything and that sort of like in in in determining whether a plaintiff has a section nineteen eighty three right or whether a plaintiff has standing, for example, you kinda have to wade into the merits just a little bit, but they wouldn't have that defense.