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FREW, on behalf of her daughter, FREW, et al. v. HAWKINS, COMMISSIONER, TEXAS HEALTH AND HUMAN SERVICES COMMISSION, et al - 540 U.S. 431 (2004)
FREW, on behalf of her daughter, FREW, et al. v. HAWKINS, COMMISSIONER, TEXAS HEALTH
AND HUMAN SERVICES COMMISSION, et al.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT
No. 02-628. Argued October 7, 2003--Decided January 14, 2004
As a participant in the Medicaid program, Texas must meet certain federal requirements, including that it have an Early and Periodic Screening, Diagnosis, and Treatment (EPSDT) program for children. The petitioners, mothers of children eligible for EPSDT services in Texas, sought injunctive relief against state agencies and various state officials, claiming that the Texas program did not meet federal requirements. The claims against the state agencies were dismissed on Eleventh Amendment grounds, but the state officials remained in the suit and entered into a consent decree approved by the Federal District Court. In contrast with the federal statute's brief and general mandate, the decree required state officials to implement many specific proposals. Two years later, when the petitioners filed an enforcement action, the District Court rejected the state officials' argument that the Eleventh Amendment rendered the decree unenforceable, found violations of the decree, and directed the parties to submit proposals outlining possible remedies. On interlocutory appeal, the Fifth Circuit reversed, holding that the Eleventh Amendment prevented enforcement of the decree because the violations of the decree did not also constitute violations of the Medicaid Act.
Held: Enforcement of the consent decree does not violate the Eleventh Amendment. Pp. 4-10.
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