Supreme Court dismisses high-profile Idaho v. United States case on procedural grounds

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Patrick Gaspard President and Chief Executive Officer at Center for American Progress | Official website

Supreme Court dismisses high-profile Idaho v. United States case on procedural grounds

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On June 27, 2024, the U.S. Supreme Court issued a 6-3 decision in Idaho v. United States that dismissed the case on procedural grounds and explicitly stated that the merits of the case would not be addressed. The court reinstated the preliminary injunction from the U.S. District Court of Idaho (Southern Division), pausing criminal and civil penalties under Idaho’s near-total abortion ban for the duration of the case.

This decision means that abortion care can be provided in Idaho as a stabilizing medical treatment under the federal Emergency Medical Treatment and Labor Act (EMTALA). Legal questions will return to lower courts, with a possibility of revisiting by the Supreme Court if an appeal arises from a future decision by the 9th U.S. Circuit Court of Appeals.

The central legal issue is whether there is a conflict between Idaho’s narrow exceptions for abortion care under its near-total ban and EMTALA's broader federally mandated requirements for emergency care. EMTALA requires hospitals participating in Medicare to provide stabilizing medical treatment, including abortion care, during emergencies.

The ruling underscores how judicial decisions impact medical practice and patient outcomes, particularly affecting vulnerable pregnant patients experiencing dire emergencies.

1. The Supreme Court vacated its own stay that impacted pregnant patients in emergencies

The majority ruled to vacate their January 5, 2024 stay which had allowed Idaho’s near-total abortion ban to take effect. This stay had altered life for pregnant patients and medical providers by suspending EMTALA’s protections previously upheld by an August 24, 2022 preliminary injunction from the U.S. District Court of Idaho (Southern Division). Following this stay, St. Luke’s hospital in Boise airlifted six patients experiencing pregnancy complications from January to April 2024 compared to only one patient throughout all of 2023 when EMTALA protections were still effective.

2. The Supreme Court acknowledged it made another “miscalculation” in dismissing certiorari as “improvidently granted”

In dismissing certiorari they originally granted on January 5, 2024, Chief Justice John Roberts and Justices Amy Coney Barrett and Brett Kavanaugh admitted a “miscalculation” due to shifts in case circumstances clarified later by DOJ filings describing EMTALA's scope as narrower than initially perceived.

3. Justice Samuel Alito’s dissent attempted to reframe EMTALA aligned with anti-abortion ideology

Justice Alito's dissent argued for a "dual stabilization requirement" under EMTALA concerning both pregnant patients and unborn children—an interpretation rebuked by the majority opinion citing errors in his analysis including inaccurate citations and oversight of congressional testimony confirming hospitals’ duty towards women whose lives or health are jeopardized.

Alito also speculated without evidence about abortions being authorized for mental health reasons under DOJ's reading of EMTALA—a claim unsupported by any real-life examples or legal filings submitted in this case.

Idaho v. United States highlights how judicial interventions can politicize medicine with significant implications for patient care during medical emergencies.

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