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Westside Mothers v. Haveman

Court of Appeals for the Sixth Circuit (2002) | 289 F.3d 852; 2002 WL 987291

4 min read

TL;DR: Medicaid recipients sued Michigan officials to compel compliance with federal law. The Sixth Circuit reversed a dismissal, holding that the suit could proceed because Spending Clause statutes are supreme federal law, the Ex parte Young doctrine overcomes sovereign immunity, and § 1983 provides a private right of action.

Legal Significance: This case strongly reaffirms that federal Spending Clause legislation is supreme law, not merely a contract, and is enforceable against state officials through prospective injunctive relief under the Ex parte Young doctrine and private suits under 42 U.S.C. § 1983, despite sovereign immunity concerns.