Moyle v. United States

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Moyle v. United States
Idaho v. United States
Supreme Court of the United States
Argued April 24, 2024
Full case nameMike Moyle, Speaker of the Idaho House of Representatives, et al. v. United States
State of Idaho v. United States
Docket nos.23-726
23-727
Case history
PriorPreliminary injunction issued (D. Idaho Aug. 24, 2022); stay pending appeal granted (9th Cir. Sep. 28, 2023); stay vacated (9th Cir. Oct. 10, 2023); stay granted and certiorari before judgment granted (Jan. 5, 2024)
Questions presented
Whether EMTALA preempts state laws that protect human life and prohibit abortions, like Idaho’s Defense of Life Act.
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Samuel Alito
Sonia Sotomayor · Elena Kagan
Neil Gorsuch · Brett Kavanaugh
Amy Coney Barrett · Ketanji Brown Jackson

Moyle v. United States is a pending United States Supreme Court case about whether an Idaho abortion law conflicts with the federal Emergency Medical Treatment and Labor Act (EMTALA).

Background

The Emergency Medical Treatment and Active Labor Act (EMTALA) was passed in 1986, and required any hospital that received federal funds through Medicare to provide a medical screening exam for anyone seeking emergency care from the hospital regardless of the person's ability to pay or other discriminatory actions.

In 2020, Idaho passed a law criminalizing most abortions. The ban, Idaho Code 18-622, was a trigger law which would only take effect if the U.S. Supreme Court overturned the constitutional right to abortion. The Supreme Court did so in Dobbs v. Jackson Women's Health Organization, ruled in June 2022, and Idaho's law was scheduled to take effect on August 25, 2022. The federal government, through the Department of Health and Human Services (HHS), issued a ruling in July 2022 in response to the Dobbs decision that because EMTALA requires hospitals receiving Medicare funds to provide "necessary stabilizing treatment" for an "emergency medical condition", such hospitals must provide abortions in cases of medical emergencies.[1][2]

The Biden administration filed a lawsuit in federal district court in Idaho, arguing that the federal statute EMTALA preempts the state law to the extent that they conflict. The administration argued that EMTALA covered abortions in situations not allowed by Idaho law, which only provides exceptions when "necessary to prevent the death of the pregnant woman", rape or incest, or an ectopic or molar pregnancy.[3][4] District judge B. Lynn Winmill agreed with the U.S. government, granting a preliminary injunction on August 24, 2022.[5] In September 2023, three-judge panel of the U.S. Court of Appeals for the Ninth Circuit granted a stay pending appeal, but the full court vacated the stay less than two weeks later.[6]

Supreme Court

The full Circuit Court's order was challenged to the Supreme Court by both the state itself and the Idaho legislature, led by Mike Moyle, the Speaker of the Idaho House of Representatives. In January 2024, the Supreme Court temporarily allowed Idaho to enforce its abortion ban, and agreed to review both petitions, consolidated under the Moyle v. United States case, on an expedited basis by granting certiorari before judgment.[7][8] The Supreme Court's action occurred days after the Fifth Circuit ruled in favor of Texas' similar law against abortions under medical emergencies, citing that the HHS had overstepped its authority in requiring these abortions to take place under EMTALA.[2]

Oral arguments were held on April 24, 2024. Joshua Turner represented council for the state of Idaho, while U.S. Solicitor General Elizabeth Prelogar represented the federal government. According to reporters, while the three liberal justices sided with the federal government's position that EMTALA overrides the Idaho law, the six conservative justices appeared split on the requirements EMTALA place on state hospitals and doctors, particularly those holding conscience objections to abortion due to their religion. The conservative justices also appeared to be concerns with the intent of the EMTALA which was meant to prevent patient dumping.[9]

References

  1. ^ 42 U.S.C. § 1395dd(b)
  2. ^ a b Pierson, Brendan (January 2, 2024). "Texas can ban emergency abortions despite federal guidance, court rules". Reuters. Retrieved January 5, 2024.
  3. ^ McShane, Julianne (September 30, 2023). "Pregnant with no OB-GYNs around: In Idaho, maternity care became a casualty of its abortion ban". NBC News. Archived from the original on January 3, 2024. Retrieved January 6, 2024.
  4. ^ Idaho Code § 18-622(2)(a) Archived 2024-01-03 at the Wayback Machine, § 18-622(2)(b),§ 18-604(1)(c) Archived 2023-12-15 at the Wayback Machine
  5. ^ Legare, Robert (August 24, 2022). "U.S. Judge rules Idaho can't criminalize abortion needed for emergency medical care". CBS News. Archived from the original on January 12, 2023. Retrieved January 6, 2024.
  6. ^ Pierson, Brendan (October 10, 2023). "Idaho abortion ban again partly halted amid appeal". Reuters. Archived from the original on 2023-11-28. Retrieved 2024-01-06.
  7. ^ Howe, Amy (January 5, 2024). "Justices take up abortion case pitting state against federal law". SCOTUSblog.
  8. ^ Sherman, Mark (January 5, 2024). "Supreme Court allows Idaho to enforce its strict abortion ban, even in medical emergencies". AP News. Archived from the original on January 6, 2024. Retrieved January 5, 2024.
  9. ^ Chung, Andrew (April 24, 2024). "US Supreme Court split over Idaho's strict abortion ban in medical emergencies". Reuters. Retrieved April 27, 2024. {{cite web}}: |first1= missing |last1= (help)
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