Moyle v. United States

603 U.S. 324 (2024) · Docket No. 23-726, 23-727

Full caption: Moyle et al. v. United States; Idaho v. United States

Writs dismissed as improvidently granted

Court
U.S. Supreme Court
Argued
April 24, 2024
Decided
June 27, 2024
Majority author
Per curiam
Vote
Per curiam dismissal of writs as improvidently granted; earlier stay vacated. Fractured: 6-3 majority to dismiss; individual concurrences and dissents

Question presented

Whether the Emergency Medical Treatment and Labor Act (EMTALA), 42 U.S.C. § 1395dd, preempts state abortion bans (specifically Idaho's Defense of Life Act) to the extent state law prohibits abortions necessary to stabilize a pregnant patient's serious medical condition short of imminent death.

Holding

The Court dismissed the writs of certiorari as improvidently granted and vacated its earlier stay, thereby reinstating the district court's preliminary injunction barring Idaho from enforcing its Defense of Life Act in EMTALA emergency situations. The Court did not decide the merits of EMTALA preemption.

Key reasoning

The Barrett/Roberts/Kavanaugh concurrence explained that Idaho had subsequently clarified its 'life of the mother' exception more broadly, and that the federal government had narrowed its EMTALA position — making the case a 'poor vehicle' for deciding the underlying preemption question.

§ 1 Reasoning

The Barrett/Roberts/Kavanaugh concurrence explained that Idaho had subsequently clarified its 'life of the mother' exception more broadly, and that the federal government had narrowed its EMTALA position — making the case a 'poor vehicle' for deciding the underlying preemption question.

§ 2 Opinions

Majority

Per curiam

Not joined by any other justice

The Court dismissed the writs of certiorari as improvidently granted and vacated its earlier stay, thereby reinstating the district court's preliminary injunction barring Idaho from enforcing its Defense of Life Act in EMTALA emergency situations. The Court did not decide the merits of EMTALA preemption.

Concurrence

Kagan, J.

Sotomayor, J.; in part Jackson, J.

Would have decided the merits and held EMTALA preempts Idaho's Defense of Life Act to the extent it prohibits abortions needed to prevent serious harm to the pregnant woman's health.

Concurrence

Barrett, J.

Roberts, C.J.; Kavanaugh, J.

Explained the DIG rationale: the case had become a 'poor vehicle' because Idaho had modified its statute and the federal government had modified its EMTALA position during litigation.

Dissent

Alito, J.

Thomas, J.; Gorsuch, J. (in part)

Would have held EMTALA does not require or authorize abortion, emphasizing EMTALA's separate protection of 'the unborn child.'

Dissent

Jackson, J.

Not joined by any other justice

Would have reached the merits and ruled for the United States; criticized the Court for 'delaying' resolution.

“Today's ruling is not a victory for pregnant patients in Idaho. It is delay.” Jackson, J. · concurring in judgment in part and dissenting in part, slip op. at 1

§ 3 Key quotes

“This Court now dismisses these cases as improvidently granted. That decision is not a victory for pregnant patients in Idaho... [it] is a signal of the Court's retreat from the difficult decision it agreed to make”
Jackson, J.slip op. (dissent in part)

§ 4 Practical effect

The federal EMTALA preemption question remains unresolved on the merits. In March 2025, the Trump DOJ dismissed the federal case; a narrower injunction now protects only St. Luke's Health System hospitals in Idaho. The question is likely to return to the Court.

§ 5 Perspectives

The summaries below are descriptive, not evaluative — an attempt to represent fairly how each camp typically frames this case.

Abolitionist framing

Abolitionists view the Alito/Thomas position — that EMTALA does not authorize abortion and separately protects 'the unborn child' under 42 U.S.C. § 1395dd(e)(1)(A)(i) — as correct. They criticize the DIG as evasion.

Mainstream pro-life framing

Mainstream pro-life groups similarly favor the Alito/Thomas reading and criticize the DIG. AUL and NRLC have pressed for legislative clarification.

Pro-choice framing

Reproductive rights advocates called the dismissal a 'punt' that left pregnant women in a legal gray zone in states with narrow life-of-mother exceptions.

§ 6 Significance

6/ 10

A DIG creates no doctrine but leaves a live circuit-level question of first-order importance. The underlying EMTALA question will almost certainly return.

Legal precedential weight4
Practical impact on access6
Movement relevance (abolitionist)6
Enduring relevance, 20268

§ 7 Sources

Editorial note The case was consolidated with Idaho v. United States. The stayed injunction was later narrowed in scope after Trump DOJ dismissal in March 2025.