--- title: "Moyle v. United States" description: "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…" type: "case" court: "U.S. Supreme Court" decided: "2024-06-27" citation: "603 U.S. 324 (2024)" docket: "23-726, 23-727" status: "Writs dismissed as improvidently granted" source_url: "https://www.abhortion.org/cases/moyle-v-united-states-2024.html" --- # Moyle v. United States _Full caption: Moyle et al. v. United States; Idaho v. United States_ **Citation:** 603 U.S. 324 (2024) · **Docket No.** 23-726, 23-727 **Status:** Writs dismissed as improvidently granted | Field | Value | | --- | --- | | Court | U.S. Supreme Court | | Argued | April 24, 2024 | | Decided | June 27, 2024 | | Vote | Per curiam dismissal of writs as improvidently granted; earlier stay vacated. Fractured: 6-3 majority to dismiss; individual concurrences and dissents | | Majority author | Per curiam | ## 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. ## 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. ## 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. _Joined by 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. _Joined by 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. _Joined by 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. ## Key quotes > "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 > "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) ## 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. ## 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. ## Significance A DIG creates no doctrine but leaves a live circuit-level question of first-order importance. The underlying EMTALA question will almost certainly return. | Measure | Score | | --- | --- | | Overall significance | 6 / 10 | | Legal precedential weight | 4 | | Practical impact on access | 6 | | Movement relevance (abolitionist) | 6 | | Enduring relevance, 2026 | 8 | ## Sources ### Primary sources - [supremecourt.gov/opinions/23pdf/23-726_6jgm.pdf](https://www.supremecourt.gov/opinions/23pdf/23-726_6jgm.pdf) ### Secondary sources - [en.wikipedia.org/wiki/Moyle_v._United_States](https://en.wikipedia.org/wiki/Moyle_v._United_States) - [constitution.congress.gov/browse/essay/intro.9-2-18/ALDE_00013905](https://constitution.congress.gov/browse/essay/intro.9-2-18/ALDE_00013905/) - [hhhealthlawblog.com/idahos-abortion-sta…](https://hhhealthlawblog.com/idahos-abortion-statute-emtala-exception-narrowed/) ## Related cases **Cites earlier cases:** - [Dobbs v. Jackson Women's Health Organization (2022)](dobbs-v-jackson-2022.md) ## Notes The case was consolidated with Idaho v. United States. The stayed injunction was later narrowed in scope after Trump DOJ dismissal in March 2025.