article: This lawsuit, filed by the General Assembly of Tennessee "General Assembly," a state senator, and state representative on their own behalf and on additionally on the behalf of the state of Tennessee, challenged the U.S. Department of State's (DOS) ability to use state funds to resettle refugees within the United States through the Refugee Act ("the Act") and the Office of Refugee Resettlement ("ORR") within the Department of Health and Human Services ("HHS"). On March 13, 2017, the General Assembly Tennessee filed a complaint in the U.S. District Court for the Western District of Tennessee seeking declaratory and injunctive relief, claiming that provisions of the Refugee Resettlement Act ("the Act") and Refugee Medical Assistance Program violated the Spending Clause and the Tenth Amendment through enacting and implementing certain statutes that require states to provide Medicaid coverage to eligible refugees. The General Assembly argued that the intent behind the Act was to avoid taxing states for what was ultimately a federal effort. Since the Act's passage in 1980, the General Assembly of Tennessee alleged that the burden on states to fund the program had increased. Moreover, the complaint argued, the state was further burdened by a requirement to cover medical costs for refugees until the state of Tennessee itself determines that a refugee is ineligible for the state Medicaid program. The state of Tennessee withdrew its participation from the refugee resettlement program in 2007. The complaint argued that the federal government nevertheless "coerced the state to continue funding" the program by threatening to withdraw federal Medicaid funding, which would amount to a 20% loss of its budget. The complaint further asserted that in establishing a private agency, Catholic Charities of Tennessee, to assume control and of the program in the state, "the federal government nullified the decision of the people of Tennessee to withdraw from an ostensibly voluntary federal program and thereby commandeered state funds to support a federal initiative." The case was reassigned to Judge S. Thomas Anderson on March 24, 2017. DOS moved to dismiss the case on June 1, 2017. DOS argued that "the refugee-coverage provision does not compel States to expend Medicaid funds for refugees; it conserves State funds by limiting to seven years the obligation the States would otherwise incur, under the Equal Protection Clause, to provide coverage to refugees on the same terms as they do U.S. citizens." Meanwhile, on June 2, 2017, the Tennessee Immigrant and Refugee Rights Coalition, Bridge Refugees Services, and the Nashville Intentional Center for Empowerment moved to intervene as defendants. Both the General Assembly and DOS filed responses in opposition to that motion to intervene. On March 19, 2018, Judge Anderson granted DOS's motion to dismiss for lack of standing on the alleged injury. 329 F.Supp.3d 597, 2018 WL 1386845. The General Assembly of Tennessee failed to establish that it has the authority on behalf of the state of Tennessee. The court also denied the intervenors' motions as moot. In his opinion, Judge Anderson held, first, that the Court lacked subject-matter jurisdiction over the case. The General Assembly of Tennessee, specifically its legislators, legislature, and Attorney General, lacked standing. The claim was not ripe because the federal government had not yet denied Medicaid funds to Tennessee and no such enforcement was imminent. Further, the Medicaid Act, which required an administrative process followed by appellate court review, precluded the claim from review in a district court. Next, Judge Anderson held that the General Assembly of Tennessee had failed to state a claim for relief under the Spending Clause or Tenth Amendment. Congress had broad powers over immigration and naturalization, including refugees' eligibility for participation in federal benefits programs. Congress had, thus, acted within its authority to set funding conditions for the States in the relevant statutes. These conditions were neither coercive nor new. The federal government had not threatened to deny funding to Tennessee. The State had, for over four decades, accepted federal Medicaid funds on the condition that it had to cover lawfully-present noncitizens, so the requirement to provide state funding for refugees in exchange for federal Medicaid funds was not a new condition. Nor should the General Assembly of Tennessee be surprised by recent fluctuations in the number of admitted refugees -- a recurring situation that the Refugee Act of 1980 anticipates. On May 10, 2018, the plaintiffs filed an appeal to the Sixth Circuit, docket #18-5478, regarding the March 19, 2018 judgement dismissing the case and denying the motion to intervene as moot. On July 24th, 2019, the United States Court of Appeals for the Sixth Circuit affirmed the lower court’s decision stating that the General Assembly was without subject-matter jurisdiction, 931 F.3d 499, 2019 WL 3310332. The Sixth Circuit held that the General Assembly had not identified an injury that it suffered, such as disruption of the legislative process, a usurpation of its authority, or nullification of anything it has done. The lower court's decision that the General Assembly was without standing to bring a case was affirmed on the basis that an alleged injury was insufficient. Therefore, the individual legislators' standing was also denied. Finally, the General Assembly did not have the authority to bring a suit in the name of the state of Tennessee. The case was closed October 24, 2019.
summary: This lawsuit, brought by the General Assembly of Tennessee in their own interests and on behalf of the state of Tennessee, challenged DOS's ability to use state funds to resettle refugees within the U.S. Tennessee maintained that provisions of the Refugee Resettlement Act and Refugee Medical Assistance Program violated the Spending Clause and 10th Amendment. In Mar. 2018, the court granted DOS' motion to dismiss and closed the case. On July 24th, 2019, the United States Court of Appeals for the Sixth Circuit filled their mandate to issue stating that the General Assembly was without subject-matter jurisdiction, affirming the lower court's decision.