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Federal judge dismisses Tennessee challenge to refugee resettlement program

[JURIST] A judge for the US District Court for the Western District of Tennessee on Monday dismissed [order] an action by the state of Tennessee against the federal refugee resettlement program.

The plaintiffs on behalf of the state of Tennessee asserted that the federal government was violating the Tenth Amendment [text] to the Constitution, reserving all powers not delegated to the federal government by the Constitution to the states. Tennessee contended that requiring the state to administer Medicaid benefits to the refugees or forfeit its annual Medicaid funds (close to $7 billion) violated the state's sovereignty.

The federal government filed a motion to dismiss for lack of subject-matter jurisdiction under Rule 12(b)(1) of the Federal Rules of Civil Procedure [text, PDF] and alternatively for failure to state a claim upon which relief can be granted under Rule 12(b)(6).

The court granted the motion to dismiss for lack of subject-matter jurisdiction based on lack of standing and ripeness of the state's claim. The laws of Tennessee confer the authority to litigate on behalf of the state to the state Attorney General who may delegate authority only to executive agencies under the Attorney General's direction. Due to the fact that the lawsuit was brought by the general assembly and other legislators it did not establish standing.

The court discussed that a future injury, such as the forfeit of Medicaid funds alleged by plaintiffs for the state, is ripe if it is "certainly impending." The court recognized that Tennessee had not submitted any amendments to the Medicaid plan denying benefits to refugees nor had Tennessee actually withheld these benefits. Additionally, the federal government has discretion to withhold all or a part of a state's Medicaid funding so the claim that the state will lose all Medicaid funding had not yet occurred nor may it ever occur.

Additionally, the court discussed the alternative motion to dismiss for failure to state a claim upon which relief may be granted. The court ruled that the plaintiffs on behalf of the state failed to show that Congress had created a coercive condition using the Medicaid funding as leverage to force states into accepting the refugee program.

The judge recognized that the requirement to provide refugees with Medicaid benefits has been well established and no additional requirements were forced on Tennessee as a prerequisite to receiving federal funding.

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