This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.
In brief
Overview
The Supreme Court held that the unnecessary‑restraint and predischarge‑notice provisions of the Federal Nursing Home Reform Act (FNHRA) create rights that are enforceable under 42 U.S.C. § 1983.
The Court declined to apply a broader reading of § 1983 and required a straightforward reading of its plain language.
Justice Thomas, joined by Justice Alito, dissented, arguing that the FNHRA cannot be enforced through § 1983.
Background and question before the Court
What each side argues
Petitioners’ Position
According to Petitioners, states are entitled to clear notice that they will be subject to private lawsuits if they accept Spending Clause money, a rule that aligns with federalism and separation‑of‑powers principles and the common‑law treatment of third‑party beneficiary claims at the time § 1983 was enacted.
Respondent’s Position
The United States agrees that the Court should not overrule decades of precedent holding that rights secured by Spending Clause laws are enforceable under § 1983, and that the FNHRA creates two enforceable rights.
What happened at oral argument
Counsel for the petitioners were Lawrence S. Robbins, Esquire (New York); Thomas M. Fisher, Solicitor General (representing Indiana and amici supporting the petitioners); and Benjamin W. Snyder, Assistant to the Solicitor General (United States amicus supporting neither party).
Thomas M. Fisher argued on behalf of Indiana and amici supporting the petitioners.
Andrew T. Tutt presented the respondent’s argument.
What the Court decided
The majority held that a straightforward reading of the plain language of § 1983 requires that the unnecessary‑restraint and predischarge‑notice provisions of the FNHRA are enforceable under § 1983.
The majority also declined to apply a broader interpretation of § 1983, emphasizing the need for a plain‑language reading.
Justice Thomas, joined by Justice Alito, dissented, arguing that the FNHRA cannot be enforced through § 1983 and that the spending power does not create private rights of action.
Why it matters
Terms to know
No glossary terms are available for this guide.
Primary sources
Read the source materials on the official site or open the immutable repository copy used for this guide.
- dc6cb097685a0b06384c-r1-73b6c5fef8c5a18d.pdforal argument transcript
- de90136e5a21a1724aea-r1-d9756d09297f785f.pdfopinion
Guide generated September 29, 2026. Automated validation accepted this version.