University of Michigan Law School
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Case Name Tennessee v. U.S. Department of State IM-TN-0006
Docket / Court 1:17-cv-01040 ( W.D. Tenn. )
State/Territory Tennessee
Case Type(s) Immigration and/or the Border
Case Summary
This lawsuit, brought by the state of Tennessee, challenged the U.S. Department of State (DOS)'s ability to use state funds to resettle refugees within the United States. On Mar. 13, 2017, Tennessee filed a complaint in the U.S. District Court for the Western District of Tennessee seeking ... read more >
This lawsuit, brought by the state of Tennessee, challenged the U.S. Department of State (DOS)'s ability to use state funds to resettle refugees within the United States. On Mar. 13, 2017, 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.

The State 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, Tennessee maintained, the burden on states to fund the program had increased. Moreover, the complaint argued, states were further burdened by a requirement to cover medical costs for refugees until the state itself determines that a refugee is ineligible for the state Medicaid program. 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 Mar. 24.

DOS moved to dismiss the case on June 1. 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, the Tennessee Immigrant and Refugee Rights Coalition, Bridge Refugees Services, and the Nashville Intentional Center for Empowerment moved to intervene as defendants. Both Tennessee and DOS filed responses in opposition to that motion to intervene.

On Mar. 19, 2018, Judge Anderson granted DOS's motion to dismiss, and denied the intervenors' motions as moot. In his opinion, Judge Anderson held, first, that the Court lacked subject-matter jurisdiction over the case. 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 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 Tennessee be surprised by recent fluctuations in the number of admitted refugees -- a recurring situation that the Refugee Act of 1980 anticipates.

The case is now closed.

Virginia Weeks - 03/27/2017
Virginia Weeks - 09/16/2017
Jamie Kessler - 08/21/2017
Ava Morgenstern - 03/24/2018


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Issues and Causes of Action
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Issues
Benefit Source
Medicaid
Constitutional Clause
Federalism
Content of Injunction
Preliminary relief denied
General
Funding
Government Services (specify)
Public benefits (includes, e.g., in-state tuition, govt. jobs)
Immigration/Border
Refugees
Medical/Mental Health
Medical care, general
Plaintiff Type
State Plaintiff
Causes of Action Declaratory Judgment Act, 28 U.S.C. § 2201
Defendant(s) United States Department of State
Plaintiff Description State of Tennessee
Class action status sought No
Class action status granted No
Filed Pro Se No
Prevailing Party Defendant
Public Int. Lawyer No
Nature of Relief None
Source of Relief None
Filing Year 2017
Case Closing Year 2018
Case Ongoing No
Additional Resources
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  U.S. judge dismisses Tennessee refugee resettlement lawsuit
www.reuters.com
Date: Mar. 19, 2018
By: Stempel, Jonathan (Reuters)
[ Detail ] [ External Link ]

Docket(s)
1:17-cv-01040 (W.D. Tenn.)
IM-TN-0006-9000.pdf | Detail
Date: 03/19/2018
Source: PACER [Public Access to Court Electronic Records]
General Documents
Complaint for Declaratory and Injunctive Relief [ECF# 1]
IM-TN-0006-0001.pdf | Detail
Date: 03/13/2017
Source: PACER [Public Access to Court Electronic Records]
Defendants' Motion to Dismiss [ECF# 24]
IM-TN-0006-0002.pdf | Detail
Date: 06/01/2017
Source: PACER [Public Access to Court Electronic Records]
Intervenor-Defendants' Motion to Intervene [ECF# 25]
IM-TN-0006-0003.pdf | Detail
Date: 06/02/2017
Source: PACER [Public Access to Court Electronic Records]
Response in Opposition to Defendants' Motion to Dismiss [ECF# 38]
IM-TN-0006-0005.pdf | Detail
Date: 07/14/2017
Source: PACER [Public Access to Court Electronic Records]
Reply Memorandum In Support of Defendants' Motion to Dismiss [ECF# 39]
IM-TN-0006-0006.pdf | Detail
Date: 08/18/2017
Source: PACER [Public Access to Court Electronic Records]
Order Granting Defendants' Motion to Dismiss and Denying Motion to Intervene as Moot [ECF# 45] (W.D. Tenn.)
IM-TN-0006-0007.pdf | Detail
Date: 03/19/2018
Source: PACER [Public Access to Court Electronic Records]
Judges Anderson, S. Thomas (W.D. Tenn.)
IM-TN-0006-0007 | IM-TN-0006-9000
Bryant, Edward G. Court not on record [Magistrate]
IM-TN-0006-9000
Plaintiff's Lawyers Brooks, Brennan Tyler (North Carolina)
IM-TN-0006-0001 | IM-TN-0006-0005 | IM-TN-0006-9000
Combs, Jay Robert (Michigan)
IM-TN-0006-0005 | IM-TN-0006-9000
Oliveri, Kate Margaret (Michigan)
IM-TN-0006-0001 | IM-TN-0006-0005 | IM-TN-0006-9000
Thompson, Richard (Michigan)
IM-TN-0006-0001 | IM-TN-0006-0005 | IM-TN-0006-9000
Defendant's Lawyers Castelli, Thomas H. (Tennessee)
IM-TN-0006-0003 | IM-TN-0006-9000
Gilligan, James J (District of Columbia)
IM-TN-0006-0002 | IM-TN-0006-0006 | IM-TN-0006-9000
Jadwat, Omar C. (New York)
IM-TN-0006-0003 | IM-TN-0006-9000
Laurenzi, Lawrence J. (Tennessee)
IM-TN-0006-0006
Readler, Chad A. (District of Columbia)
IM-TN-0006-0006
Ricketts, Jennifer (District of Columbia)
IM-TN-0006-0006
Robinson, Stuart Justin (California)
IM-TN-0006-0002 | IM-TN-0006-0006 | IM-TN-0006-9000
Wofsy, Cody H. (California)
IM-TN-0006-0003 | IM-TN-0006-9000

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