Moyle v. United States: Difference between revisions
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Lost Student (talk | contribs) (Created page with "{{Infobox Case Brief |court=U.S. Supreme Court |citation=Dkt. No. 23-726 |subject=Health Law |other_subjects=Constitutional Law |appealed_from=U.S. Court of Appeals, Ninth Circuit |related=Dobbs v. Jackson Women’s Health Organization* Roe v. Wade |facts=In August 2022, after the Supreme Court’s decision in ''Dobbs v. Jackson Women’s Health Organization'', which eliminated the constitutional right to an abortion, the Biden administration brought a legal challeng...") |
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|appealed_from=U.S. Court of Appeals, Ninth Circuit | |appealed_from=U.S. Court of Appeals, Ninth Circuit | ||
|related=Dobbs v. Jackson Women’s Health Organization* Roe v. Wade | |related=Dobbs v. Jackson Women’s Health Organization* Roe v. Wade | ||
|facts=In August 2022, after the Supreme Court’s decision in ''[[Dobbs v. Jackson Women’s Health Organization]]'', which eliminated the constitutional right to an abortion, the Biden administration brought a legal challenge to a restrictive Idaho abortion law. Idaho is one of seven states to put an abortion ban in place since ''[[Dobbs v. Jackson Women’s Health Organization|Dobbs]]''. Idaho's ban allows abortions if necessary to save the life of the mother, but there is no exception to protect her health.<ref>https://www.nbcnews.com/news/us-news/idahos-abortion-emergency-supreme-court-airlifted-rcna148828</ref> | |facts=In August 2022, after the Supreme Court’s decision in ''[[Dobbs v. Jackson Women’s Health Organization]]'', which eliminated the constitutional right to an abortion, the Biden administration brought a legal challenge to a restrictive Idaho abortion law, the Defense of Life Act.<ref>https://legislature.idaho.gov/statutesrules/idstat/Title18/T18CH6/SECT18-622/</ref> Idaho is one of seven states to put an abortion ban in place since ''[[Dobbs v. Jackson Women’s Health Organization|Dobbs]]''. Idaho's ban allows abortions if necessary to save the life of the mother, but there is no exception to protect her health.<ref>https://www.nbcnews.com/news/us-news/idahos-abortion-emergency-supreme-court-airlifted-rcna148828</ref> | ||
The Biden administration argued that the state law, which criminalizes providing an abortion except in a few narrow circumstances, including to save the life of the mother, is preempted by a federal law, the Emergency Medical Treatment and Labor Act (EMTALA). EMTALA requires hospitals receiving Medicare funding to offer "necessary stabilizing treatment" to pregnant women in emergencies. EMTALA expressly provides that it does not trump any requirement imposed by state or local law "except to the extent that the requirement directly conflicts with a requirement" imposed by EMTALA. | The Biden administration argued that the state law, which criminalizes providing an abortion except in a few narrow circumstances, including to save the life of the mother, is preempted by a federal law, the Emergency Medical Treatment and Labor Act (EMTALA).<ref>[https://uscode.house.gov/view.xhtml?req=(title:42%20section:1395dd%20edition:prelim) Emergency Medical Treatment and Labor Act (EMTALA), 42 U.S.C. § 1395dd]</ref> EMTALA requires hospitals receiving Medicare funding to offer "necessary stabilizing treatment" to pregnant women in emergencies. EMTALA expressly provides that it does not trump any requirement imposed by state or local law "except to the extent that the requirement directly conflicts with a requirement" imposed by EMTALA. | ||
|procedural_history=The district court ruled in favor of the Biden administration and barred Idaho from enforcing its law to the extent that it conflicted with EMTALA. The U.S. Court of Appeals for the Ninth Circuit, sitting ''en banc'', declined to stay the district court's ruling | |procedural_history=The district court ruled in favor of the Biden administration and barred Idaho from enforcing its law to the extent that it conflicted with EMTALA.<ref>Specifically, Idaho was "prohibited from initiating any criminal prosecution against, attempting to suspend or revoke the professional license of, or seeking to impose any other form of liability on, any medical provider or hospital based on their performance of conduct that (1) is defined as an 'abortion' under Idaho Code § 18-604(1), but that is necessary to avoid (i) 'placing the health of' a pregnant patient 'in serious jeopardy'; (ii) a 'serious impairment to bodily functions' of the pregnant patient; or (iii) a 'serious dysfunction of any bodily organ or part' of the pregnant patient, pursuant to 42 U.S.C. § 1395dd(e)(1)(A)(i)-(iii)." [https://www.courthousenews.com/wp-content/uploads/2022/08/usa-vs-idaho-abortion-law-memorandum-decision-and-order.pdf Memorandum Decision and Order]</ref> | ||
The U.S. Court of Appeals for the Ninth Circuit, sitting ''en banc'', declined to stay the district court's ruling when Idaho appealed. | |||
Moyle and Idaho both petitioned the U.S. Supreme Court on November 20, 2023 to stay the district court’s injunction. Moyle's petition was issued Dkt. No. 23-726 and Idaho's was issued Dkt. No. 23-727. The petitions were granted on Jan. 5, 2024. The petitions were also treated as petitions for a writ of certiorari, which were also granted, with time allotted for oral argument.<ref>https://www.supremecourt.gov/docket/docketfiles/html/public/23-726.html</ref><ref>https://www.supremecourt.gov/docket/docketfiles/html/public/23-727.html</ref> | |||
|issues=Does the federal Emergency Medical Treatment and Labor Act preempt an Idaho law that criminalizes most abortions in that state? | |issues=Does the federal Emergency Medical Treatment and Labor Act preempt an Idaho law that criminalizes most abortions in that state? | ||
|arguments='''Idaho argued''' that there is no direct conflict between EMTALA and its abortion ban because EMTALA simply bars affected emergency rooms from refusing to serve lower-income or uninsured patients. ERs must screen and stabilize patients before transferring or discharging them. Idaho further argued that since the ban allows abortions if necessary to save the life of the mother, any abortion needed to satisfy EMTALA would be allowed under the abortion ban. Interpreting the EMTALA to require abortions would violate the '''[[Constitution of the United States/Art. I/Section 1 Legislative Vesting Clause#Major Questions Doctrine and Canons of Statutory Construction|major questions doctrine]]'''<ref>See also [[Constitution of the United States/Art. II/Sec. 1/Clause 1 President's Role#Major Questions Doctrine and Administrative Agencies|Major Questions Doctrine and Administrative Agencies]]</ref> – the idea that the Executive Branch cannot interpret ambiguous legislation to effectuate sweeping changes of national consequence. Instead, Congress must, at a minimum, provide clear authorization that it intends to grant the Executive Branch such far-reaching powers. | |arguments='''Idaho argued''' that there is no direct conflict between EMTALA and its abortion ban because EMTALA simply bars affected emergency rooms from refusing to serve lower-income or uninsured patients. ERs must screen and stabilize patients before transferring or discharging them. Idaho further argued that since the ban allows abortions if necessary to save the life of the mother, any abortion needed to satisfy EMTALA would be allowed under the abortion ban. Interpreting the EMTALA to require abortions would violate the '''[[Constitution of the United States/Art. I/Section 1 Legislative Vesting Clause#Major Questions Doctrine and Canons of Statutory Construction|major questions doctrine]]'''<ref>See also [[Constitution of the United States/Art. II/Sec. 1/Clause 1 President's Role#Major Questions Doctrine and Administrative Agencies|Major Questions Doctrine and Administrative Agencies]]</ref> – the idea that the Executive Branch cannot interpret ambiguous legislation to effectuate sweeping changes of national consequence. Instead, Congress must, at a minimum, provide clear authorization that it intends to grant the Executive Branch such far-reaching powers. | ||
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==See Also== | |||
* [https://crsreports.congress.gov/product/pdf/IF/IF12355 Congressional Research Service Overview of EMTALA and Emergency Abortion Services] | |||
==References== | ==References== | ||
{{Reflist|2}} | {{Reflist|2}} | ||
Latest revision as of 21:09, April 26, 2024
| Moyle v. United States | |
| Court | U.S. Supreme Court |
|---|---|
| Citation | Dkt. No. 23-726 |
| Date decided | |
| Appealed from | U.S. Court of Appeals, Ninth Circuit |
| Related | Dobbs v. Jackson Women’s Health Organization Roe v. Wade |
Facts
In August 2022, after the Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, which eliminated the constitutional right to an abortion, the Biden administration brought a legal challenge to a restrictive Idaho abortion law, the Defense of Life Act.[1] Idaho is one of seven states to put an abortion ban in place since Dobbs. Idaho's ban allows abortions if necessary to save the life of the mother, but there is no exception to protect her health.[2]
The Biden administration argued that the state law, which criminalizes providing an abortion except in a few narrow circumstances, including to save the life of the mother, is preempted by a federal law, the Emergency Medical Treatment and Labor Act (EMTALA).[3] EMTALA requires hospitals receiving Medicare funding to offer "necessary stabilizing treatment" to pregnant women in emergencies. EMTALA expressly provides that it does not trump any requirement imposed by state or local law "except to the extent that the requirement directly conflicts with a requirement" imposed by EMTALA.Procedural History
The district court ruled in favor of the Biden administration and barred Idaho from enforcing its law to the extent that it conflicted with EMTALA.[4]
The U.S. Court of Appeals for the Ninth Circuit, sitting en banc, declined to stay the district court's ruling when Idaho appealed.
Moyle and Idaho both petitioned the U.S. Supreme Court on November 20, 2023 to stay the district court’s injunction. Moyle's petition was issued Dkt. No. 23-726 and Idaho's was issued Dkt. No. 23-727. The petitions were granted on Jan. 5, 2024. The petitions were also treated as petitions for a writ of certiorari, which were also granted, with time allotted for oral argument.[5][6]Issues
Does the federal Emergency Medical Treatment and Labor Act preempt an Idaho law that criminalizes most abortions in that state?
Arguments
Idaho argued that there is no direct conflict between EMTALA and its abortion ban because EMTALA simply bars affected emergency rooms from refusing to serve lower-income or uninsured patients. ERs must screen and stabilize patients before transferring or discharging them. Idaho further argued that since the ban allows abortions if necessary to save the life of the mother, any abortion needed to satisfy EMTALA would be allowed under the abortion ban. Interpreting the EMTALA to require abortions would violate the major questions doctrine[7] – the idea that the Executive Branch cannot interpret ambiguous legislation to effectuate sweeping changes of national consequence. Instead, Congress must, at a minimum, provide clear authorization that it intends to grant the Executive Branch such far-reaching powers.
The U.S. argued that the issue is narrower than argued by Idaho: the question before the Court is whether states "can deny pregnant women essential medical care to prevent grave harm to their health notwithstanding EMTALA's stabilization mandate." The purpose of EMTALA is much broader than argued by Idaho, and actually "promises essential emergency care to all Americans." EMTALA could require the termination of a pregnancy as stabilizing treatment to prevent serious harm to the woman’s health (but not her death). Under the current law, hospitals in Idaho are forced to transport some patients out of state so they can receive an abortion to prevent serious harm to her health, which puts EMTALA in direct conflict with the Idaho abortion ban.Comments
The Supreme Court heard oral arguments on this case on April 24, 2024. A decision should be issued in late June or early July.
The petitioners were Mike Moyle, Speaker of the Idaho House of Representatives, and Idaho. Arguing for the petitioners was Joshua N. Turner, a lawyer with the Idaho Attorney General's office. Arguing for the U.S. was Elizabeth B. Prelogar, the U.S. Solicitor General and a native of Idaho.Resources
See Also[edit | edit source]
References[edit | edit source]
- ↑ https://legislature.idaho.gov/statutesrules/idstat/Title18/T18CH6/SECT18-622/
- ↑ https://www.nbcnews.com/news/us-news/idahos-abortion-emergency-supreme-court-airlifted-rcna148828
- ↑ Emergency Medical Treatment and Labor Act (EMTALA), 42 U.S.C. § 1395dd
- ↑ Specifically, Idaho was "prohibited from initiating any criminal prosecution against, attempting to suspend or revoke the professional license of, or seeking to impose any other form of liability on, any medical provider or hospital based on their performance of conduct that (1) is defined as an 'abortion' under Idaho Code § 18-604(1), but that is necessary to avoid (i) 'placing the health of' a pregnant patient 'in serious jeopardy'; (ii) a 'serious impairment to bodily functions' of the pregnant patient; or (iii) a 'serious dysfunction of any bodily organ or part' of the pregnant patient, pursuant to 42 U.S.C. § 1395dd(e)(1)(A)(i)-(iii)." Memorandum Decision and Order
- ↑ https://www.supremecourt.gov/docket/docketfiles/html/public/23-726.html
- ↑ https://www.supremecourt.gov/docket/docketfiles/html/public/23-727.html
- ↑ See also Major Questions Doctrine and Administrative Agencies
