The opinion is also significant because the Court, without discussion, permitted a Medicaid suit to proceed where the cause of action was conferred by the Supremacy Clause. Most federal suits alleging violation of the Medicaid Act – which does not expressly confer a right of action – claim that the right of action is authorized by 42 U.S.C. § 1983. In recent years, the Supreme Court has made it more difficult to sue under § 1983 for statutory violations, requiring that the statutory provision in question unmistakably focus on individual rights. While some Medicaid suits have been permitted under § 1983, certain Medicaid provisions have been held unenforceable.