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Case Digest on Health and Hospital Corporation of Marion County et al. v. Talevski

Case Digest on Health and Hospital Corporation of Marion County et al. v. Talevski
The Supreme Court held that provisions of the Federal Nursing Home Reform Act (FNHRA) create rights enforceable under §1983, affirming the right of nursing home residents to sue state actors for violations of federal law.


This case addresses the intersection of federal statutory rights and the ability of individuals to seek redress under §1983 for violations of those rights by state actors, specifically in the context of nursing home care.

Facts of the Case:

Gorgi Talevski, after being moved to a county-owned nursing home, experienced a decline in health due to the alleged use of chemical restraints and attempts to transfer him without proper notice. His family sued under §1983, claiming violations of the FNHRA.

Issue of the Case:

Whether provisions of the FNHRA can be enforced by individuals under §1983 against state actors.

Ruling of the Case:

The Supreme Court affirmed that the contested FNHRA provisions unambiguously confer rights that are enforceable under §1983, rejecting arguments against this interpretation based on the statute's enactment under Congress's spending power.

This ruling emphasizes the enforceability of federal statutory rights under §1983 and underscores the role of federal law in protecting individuals in state-run facilities.


The decision reinforces the mechanism of §1983 as a vital tool for individuals to enforce federally guaranteed rights, particularly in the context of nursing home care and potentially beyond.