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Source and Scope of Public Health Legal Powers

Doyle v. Tidball

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Overview

Doyle v. Tidball (Supreme Court of Missouri, July 22, 2021): Plaintiffs, residents of Missouri, sued the state Department of Social Services (DSS) after it refused to provide them with Medicaid coverage. Residents claimed they were eligible for coverage under a newly enacted article to the state’s constitution, but after the state legislature proposed appropriating money through bills which did not reference the new provision, DSS withdrew its proposed plan to comply with the article. Plaintiffs argued that DSS’s actions violated the constitutional provision. The lower court ruled the provision was unconstitutional because it appropriated funds without creating revenue. Plaintiffs appealed, and the Missouri Supreme Court reversed in part, finding that the provision was constitutional. While it required the spending of money, it still reserved the legislature’s discretionary power to decide “whether and to what extent it will appropriate money” for the programs. Read the full decision here.

View all cases in the Judicial Trends in Public Health – October 15, 2021.

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