Health and Hospital Corporation of Marion Cty. v. Talevski

The Court decided that two Federal Nursing Home Reform Act protections—against improper transfers or discharges and unnecessary chemical restraints—create rights that people may enforce under Section 1983 (a federal civil-rights law). It affirmed the Seventh Circuit's decision for Talevski's family.

The Court ruled 7-2 in an opinion by Justice Ketanji Brown Jackson, joined by Justices Sotomayor, Kagan, and Kavanaugh. Justice Gorsuch and Justice Barrett wrote concurrences, and Chief Justice Roberts also concurred; Justices Thomas and Alito each wrote dissents.

Majority

Jackson

Roberts

Sotomayor

Kagan

Gorsuch

Kavanaugh

Barrett

Dissent

Thomas

Alito

“The provisions at issue “unambiguously create §1983-enforceable rights.””

Nursing-home residents and their families can bring Section 1983 claims against state-run facilities for violations of these protections. For example, a resident alleging unnecessary chemical restraints may seek to enforce the federal right in court.

Lower courts must apply the decision when residents bring these Section 1983 claims. State-run nursing facilities and agencies must account for the possibility of federal lawsuits over the transfer, discharge, and medication protections.

The Court ruled that the Federal Nursing Home Reform Act provisions at issue create individual rights enforceable through Section 1983.

Residents of state-run nursing facilities and their families may bring federal claims over improper discharges, transfers, or unnecessary chemical restraints.

Lower courts will apply the ruling to future claims. State-run facilities may face lawsuits alleging violations of these federal resident protections.