Lancaster v. Cartmell and the End of § 1983 Enforcement of Medicaid’s “Reasonable Promptness” Provision in the Tenth Circuit

I. Introduction

In Lancaster v. Cartmell, No. 25‑6000 (10th Cir. Dec. 23, 2025) (published), the Tenth Circuit held that Medicaid’s “reasonable promptness” requirement, 42 U.S.C. § 1396a(a)(8), does not create a privately enforceable right under 42 U.S.C. § 1983.

The decision is an important application—and extension—of the Supreme Court’s then‑recent decision in Medina v. Planned Parenthood South Atlantic, 606 U.S. 357 (2025). While the district court had dismissed the case because it agreed the plaintiffs were ineligible for Medicaid on financial‑eligibility grounds, the Tenth Circuit affirmed on a different, more structural basis: even if the Lancasters had been eligible, they could not use § 1983 to enforce § 1396a(a)(8) at all.

This commentary explains the background of the dispute, summarizes the opinion, and then analyzes in depth how Lancaster uses Medina to close off a historically important avenue for Medicaid beneficiaries in the Tenth Circuit: private enforcement of the federal “reasonable promptness” requirement. It also explores the case’s interaction with older precedents such as Wright, Wilder, and Blessing, and with the Third Circuit’s influential—but now deeply undermined—decision in Sabree v. Richman, 367 F.3d 180 (3d Cir. 2004).

II. Background of the Case

A. Parties and Factual Context

Max and Peggy Lancaster were Oklahoma residents who sought Medicaid benefits for long‑term care. Before applying, they transferred approximately $3.8 million in real and personal property to “The Lancaster Family LLC,” a limited liability company owned by their three adult children. In exchange, the LLC executed:

• a loan agreement,
• real estate mortgages,
• personal guarantees, and
• a promissory note.

When the Lancasters later applied for Medicaid, Oklahoma’s agencies—the Department of Human Services (DHS) and the Oklahoma Health Care Authority (OHCA)—found them ineligible. Central to that determination was the agencies’ conclusion that the LLC’s promissory note was not a “bona fide” loan.

The agencies relied on Social Security Administration guidance in the Program Operations Manual System (POMS), specifically POMS SI § 1120.220(B)(3), which treats a loan as bona fide only if it is “legally valid under the applicable State’s law and made in good faith.” Because the promissory note was deemed not bona fide, it counted as a “resource” for Medicaid eligibility. In other words, the value transferred to the LLC was not effectively removed from the Lancasters’ countable assets. Their resources therefore exceeded Medicaid’s asset limit, making them ineligible.

B. Procedural History

1. District court proceedings. The Lancasters sued the directors of DHS and OHCA in their official capacities under 42 U.S.C. § 1983 in the U.S. District Court for the Western District of Oklahoma. They alleged that by denying their applications on the basis of an erroneous asset determination, the agencies had violated 42 U.S.C. § 1396a(a)(8), which obliges state Medicaid plans to furnish assistance “with reasonable promptness to all eligible individuals.”
   
   The agencies moved to dismiss, arguing among other things that:
   • the promissory note was a countable resource, so the Lancasters were ineligible; and
   • their denial of benefits therefore did not violate § 1396a(a)(8).
   The district court agreed with the agencies’ eligibility analysis and granted the motion to dismiss.
2. Appeal and supervening Supreme Court decision. The Lancasters appealed. While the appeal was pending, the Supreme Court decided Medina v. Planned Parenthood South Atlantic, 606 U.S. 357 (2025). Medina held that Medicaid’s “any‑qualified‑provider” provision, 42 U.S.C. § 1396a(a)(23)(A), does not clearly and unambiguously confer an individually enforceable right under § 1983.
   
   Seeing Medina as a game‑changer, the state agencies moved for summary disposition in the Tenth Circuit under Federal Rule of Appellate Procedure 27 and Tenth Circuit Rule 27.3(A)(1)(b), arguing that:
   • Medina was a “supervening change in law” affecting all Medicaid private‑enforcement claims under § 1983;
   • like § 1396a(a)(23)(A), § 1396a(a)(8) is a Spending Clause condition; and
   • therefore § 1396a(a)(8) also lacks “rights‑creating” language and cannot be enforced via § 1983.
   The Lancasters opposed summary disposition, contending that:
   • Medina merely clarified existing law and was not a “supervening” change; and
   • § 1396a(a)(8) is materially different from § 1396a(a)(23)(A), and had been held enforceable by the Third Circuit in Sabree.
   The Tenth Circuit denied the motion for summary disposition, but proceeded to decide those issues in its full, published opinion.
3. The death of Mrs. Lancaster. Mrs. Lancaster died during the litigation. The agencies argued her claims should be dismissed. The panel noted the argument in a footnote but declined to address it because its disposition on independent legal grounds (no private right under § 1983) made the question unnecessary to resolve.

III. Summary of the Opinion

Judge Tymkovich, writing for a unanimous panel (Judges Tymkovich, Phillips, and McHugh), affirmed the district court’s dismissal but on a different ground:

• The panel held that 42 U.S.C. § 1396a(a)(8) does not “clearly and unambiguously” confer a privately enforceable federal right for Medicaid applicants or beneficiaries, and therefore cannot be enforced through 42 U.S.C. § 1983.
• This conclusion rested squarely on Medina’s reformulation of the standard for determining whether Spending Clause statutes (like Medicaid) create rights enforceable under § 1983.
• The court:
  • summarized Medina’s framework for assessing whether a statute uses “rights‑creating terms” with an “unmistakable focus on individuals”;
  • emphasized that rights under Spending Clause statutes are “rare exceptions”;
  • applied that framework to § 1396a(a)(8) and found it wanting; and
  • explicitly rejected reliance on the Third Circuit’s decision in Sabree v. Richman, which had held that § 1396a(a)(8) is privately enforceable under § 1983.
• Because the court found no enforceable right, it did not reach:
  • whether the Lancasters were in fact financially ineligible under federal and state Medicaid rules; or
  • whether the agencies misapplied POMS or improperly treated the LLC transaction as a countable resource.

The holding, in a single sentence, is in the opinion’s conclusion: “We affirm because § 1396a(a)(8) does not confer an individual right enforceable by the Lancasters through § 1983.”

IV. Detailed Analysis

A. Precedents and Doctrinal Context

1. Section 1983 and Private Statutory Rights

42 U.S.C. § 1983 creates a cause of action against state actors who, under color of state law, violate “rights, privileges, or immunities secured by the Constitution and laws” of the United States. Two key points follow:

1. Not every federal statute creates a “right.” A statute can impose duties, create benefits, or set standards without granting individuals enforceable federal “rights.” Section 1983 is available only when the statute confers such rights.
2. Courts must distinguish “rights” from mere “benefits” or “interests.” As the Supreme Court reiterated in Medina (citing Health & Hosp. Corp. of Marion Cty. v. Talevski, 599 U.S. 166 (2023)), a plaintiff suing under § 1983 must show that the statute “secures an enforceable right, privilege, or immunity, and does not just provide a benefit or protect an interest.”

The modern line of cases concerns how to tell when a statute creates such a right. Medina sharpened that inquiry and Lancaster applies it.

2. Spending Clause Statutes and the “Contract” Analogy

The Medicaid Act is a classic Spending Clause statute, enacted pursuant to Congress’s power to spend for the general welfare. As Medina (and before it, Pennhurst State School & Hosp. v. Halderman, 451 U.S. 1 (1981)) explained:

• Congress offers federal funds to States;
• States voluntarily accept those funds by agreeing to comply with conditions set out in the statute; and
• the arrangement is “in the nature of a contract” between the federal government and the State.

In such a scheme, the “typical remedy” for a State’s failure to comply with funding conditions is for the federal government to withhold or terminate funds—not for private individuals to bring enforcement suits. The Court in Medina underscored that:

“[T]he statutes address a State’s obligations to the federal government, not the rights of any particular person.” (quoting Gonzaga Univ. v. Doe, 536 U.S. 273, 288 (2002)).

Accordingly, the Court made clear that a private party may sue to enforce a condition in a federal grant program only if:

• Congress has given States “clear and unambiguous notice” that accepting the funds also means consenting to private suits under § 1983 for violations of that condition.

This “notice” requirement derives from the analogy to contracts: a party cannot be bound to a “term” of the contract—here, exposure to private § 1983 lawsuits—unless the term was part of the bargain the party knowingly accepted.

3. Gonzaga and the Rejection of Earlier Expansive Approaches

The Supreme Court’s earlier Spending Clause/§ 1983 cases—Wright v. Roanoke Redevelopment & Hous. Auth., 479 U.S. 418 (1987), Wilder v. Va. Hosp. Ass’n, 496 U.S. 498 (1990), and Blessing v. Freestone, 520 U.S. 329 (1997)—took a comparatively expansive view of when statutes conferred enforceable rights.

• Wright recognized a private right under § 1983 to enforce a statutory cap on public housing rents.
• Wilder found that a Medicaid reimbursement provision was enforceable by hospitals under § 1983, focusing on whether the statute was “intended to benefit the putative plaintiff” and whether the interest was not “too vague and amorphous.”
• Blessing articulated a three‑factor test for identifying enforceable rights, asking whether:
  1. the plaintiff is an intended beneficiary of the statute;
  2. the asserted right is specific, not “vague or amorphous”; and
  3. the statute imposes a binding obligation on the States.

Later, Gonzaga Univ. v. Doe, 536 U.S. 273 (2002), narrowed this approach, requiring:

• rights‑creating language that “unambiguously” focuses on the individuals protected; and
• a text that “clearly” manifests an intent to create an individual entitlement enforceable under § 1983, rather than merely imposing obligations on regulated entities or on States in the aggregate.

Medina then clarified how Gonzaga interacts with those earlier cases. The Court in Medina acknowledged that it had briefly “experimented with a different approach” and that this had sown confusion. It then gave explicit instructions to lower courts:

“To the extent lower courts feel obliged, or permitted, to consider the contrary reasoning of Wilder, Wright, or Blessing, they should resist the impulse.”

Thus, while Wright and Wilder remain technically on the books, their reasoning is no longer a legitimate guide for determining whether Spending Clause statutes confer private rights enforceable under § 1983. Blessing’s three‑factor test, rooted in that same approach, is likewise sidelined.

4. Medina v. Planned Parenthood South Atlantic

In Medina, the Supreme Court addressed whether the Medicaid Act’s “any‑qualified‑provider” provision, 42 U.S.C. § 1396a(a)(23)(A), creates a § 1983‑enforceable right:

“any individual eligible for medical assistance (including drugs) may obtain such assistance from any institution, agency, community pharmacy, or person, qualified to perform the service or services required … who undertakes to provide him such services.”

The Court distilled the test as follows:

• To prove that a statute secures an enforceable right (not merely a benefit or interest), a plaintiff must show that the statute:
  • “clearly and unambiguously” uses “rights‑creating terms”; and
  • has an “unmistakable focus on individuals like the plaintiff.”
• This is a “stringent” and “demanding” test, especially in Spending Clause statutes.
• Even if such rights exist, § 1983 actions may be displaced if Congress has supplied an alternative, more specific remedial scheme. (citing Rancho Palos Verdes v. Abrams, 544 U.S. 113 (2005)).

Applying this to § 1396a(a)(23)(A), the Court emphasized:

• The provision is located in § 1396a(a), under the heading “Contents,” which lists conditions that a state “plan must” contain to qualify for federal funds.
• Section 1396c directs the Secretary of Health and Human Services to monitor States’ “substantial compliance” with these conditions and to withhold funds when States fail to comply in the aggregate.
• This structural context—obligations phrased in terms of what a “State plan must” do, overseen by the Secretary for “aggregate compliance”—“suggests that the statute addresses a State’s obligations to the federal government, not the rights of any particular person.”
• The fact that the provision benefits patients or providers does not transform it into a privately enforceable right.
• Mandatory wording such as “must” or “shall” is insufficient by itself to create an enforceable individual right.

The Court concluded that rights‑creating provisions in Spending Clause statutes are “atypical” and that § 1396a(a)(23)(A) was not one of them. Accordingly, it held that the provision does not confer an individually enforceable right under § 1983.

5. Sabree v. Richman and its Fate After Medina

The Lancasters relied heavily on the Third Circuit’s decision in Sabree v. Richman, 367 F.3d 180 (3d Cir. 2004), which had held that § 1396a(a)(8) does confer a private right of action under § 1983.

The Third Circuit in Sabree explicitly applied the Blessing test (derived from Wright, Wilder, and Suter v. Artist M., 503 U.S. 347 (1992)) and then, in light of Gonzaga, concluded that:

• the statute used mandatory language (“a State plan must provide”); and
• it focused on “all eligible individuals,” i.e., identifiable beneficiaries.

The Third Circuit further noted that the Supreme Court had not overruled Wright and Wilder, treating their continued existence as reinforcing its conclusion that provisions like § 1396a(a)(8) create enforceable rights.

Lancaster holds that this reasoning is no longer tenable after Medina:

• Sabree is built directly on Wright, Wilder, and Blessing—cases whose reasoning Medina has expressly told lower courts to avoid using as a guide for Spending Clause rights.
• Reliance on mandatory language like “must” is insufficient under Medina, which cautions that mandatory terms alone do not create private rights.
• Focusing on statutory “beneficiaries” (such as “eligible individuals”) is not enough; the text must show an “unmistakable focus on individuals” in rights‑creating terms, not simply confer benefits incidentally.

The Tenth Circuit therefore expressly declines to follow Sabree, treating it as inconsistent with the Supreme Court’s clarified approach in Medina.

B. The Tenth Circuit’s Legal Reasoning in Lancaster

1. The Statute at Issue: 42 U.S.C. § 1396a(a)(8)

Section 1396a(a) sets out what “[a] State plan for medical assistance must” contain to qualify for federal Medicaid funding. The specific provision at issue, § 1396a(a)(8), states (in relevant part) that a state plan must:

“provide that all individuals wishing to make application for medical assistance under the plan shall have opportunity to do so, and that such assistance shall be furnished with reasonable promptness to all eligible individuals.”

The Lancasters alleged that the Oklahoma agencies violated this provision by:

• erroneously treating the promissory note as a countable resource; and
• thus wrongfully deciding they were not “eligible” and failing to furnish assistance with “reasonable promptness.”

Critically, however, the Tenth Circuit did not decide whether the Lancasters were actually eligible or whether the agencies complied with the substantive Medicaid eligibility rules. Instead, it asked whether § 1396a(a)(8) is even enforceable by private plaintiffs via § 1983.

2. Medina’s Applicability to § 1396a(a)(8)

The panel emphasized that § 1396a(a)(8) shares the same structural features as the provision addressed in Medina:

• Both provisions are located in § 1396a(a) under “Contents,” which lists the conditions state plans “must” meet to qualify for funds.
• Both are enforced primarily through § 1396c, which requires States to “comply substantially” with these conditions and authorizes the Secretary to terminate funds for noncompliance.
• Both are, in the Court’s words, “requirements directed to the Secretary of Health and Human Services for plan approvals,” rather than explicit conferrals of rights to individuals.

The court then applied Medina’s guiding principles:

• Spending Clause exceptionalism. Because Medicaid is Spending Clause legislation, “rights‑creating provisions are rare exceptions.” Like the neighboring any‑qualified‑provider clause, § 1396a(a)(8) must be treated as presumptively not rights‑creating unless the text unmistakably says otherwise.
• Mandatory language is insufficient. Although § 1396a(a)(8) uses somewhat more mandatory phrasing than § 1396a(a)(23)(A) (for example, “must … provide” that assistance “shall be furnished”), Medina teaches that words like “must” and “shall” alone do not create rights. They often just indicate duties within a regulatory or contractual scheme.
• Focus on state plans, not individual entitlements. The provision describes what a “State plan … must” do, rather than stating that “each individual shall have the right to” certain promptness or to sue for its denial. The focus, as Medina would put it, is on state compliance in the aggregate, not on an individual’s federal right.

From this, the panel concluded that § 1396a(a)(8) is materially indistinguishable from § 1396a(a)(23)(A) for purposes of the Medina analysis. If the latter does not create an enforceable right, neither does the former.

3. Rejection of Sabree’s Reasoning

The Lancasters argued that Sabree had already held § 1396a(a)(8) enforceable under § 1983 after Gonzaga, and that Medina simply reaffirmed Gonzaga. The Tenth Circuit responded in several steps.

1. Sabree leans heavily on disfavored precedents. Sabree explicitly grounded its analysis in Wright, Wilder, and Blessing as “construed by Gonzaga.” But Medina instructs lower courts not to rely on those earlier, more expansive approaches to Spending Clause rights, calling the Court’s prior repudiation of their reasoning “longstanding.”
2. The Blessing test is no longer the guide. Sabree used the three‑prong Blessing test (intended beneficiaries, non‑vague rights, binding obligations) to determine that § 1396a(a)(8) created rights. Yet Medina explains that Blessing grew out of the now‑disfavored, more expansive view of the Court’s power to imply private rights under Spending Clause statutes. The panel in Lancaster thus reads Medina as effectively discrediting Blessing as a controlling analytic framework.
3. Mandatory language and references to “eligible individuals” are not enough. Sabree gave weight to the provision’s mandatory phrasing (“must provide”) and its reference to “all eligible individuals” as evidence of a rights‑creating focus. Lancaster, following Medina, holds that:
   • mandatory verbs do not necessarily signify rights; and
   • even a provision that benefits individuals or mentions them directly can still be oriented toward regulating state obligations within a federal‑state funding contract, rather than granting enforceable rights.
4. Medina displaces Sabree’s underlying rationale. The Tenth Circuit notes that Sabree took comfort from the fact that the Supreme Court had not overruled Wright and Wilder, treating that silence as a signal that similar provisions could still be enforceable. After Medina emphasized its “longstanding repudiation” of the reasoning in those cases, that comfort is gone.

The court concludes bluntly: “given the Court’s directives in Medina, the analysis in Sabree cannot withstand scrutiny.”

4. Disposition on Remedial Grounds

Having determined that § 1396a(a)(8) does not create a private right enforceable under § 1983, the panel:

• does not review the district court’s reasoning about the bona fides of the promissory note or the Lancasters’ financial eligibility;
• does not reach the question whether Mrs. Lancaster’s death requires dismissal of her claims; and
• affirms solely because the plaintiffs lack an enforceable federal right under § 1396a(a)(8) that could support a § 1983 claim.

This illustrates a common pattern in modern federal rights litigation: courts may sidestep substantive entitlement disputes by concluding that the plaintiffs have no federal cause of action to enforce the relevant statutory provision at all.

C. Impact and Implications

1. Immediate Consequences for Medicaid Beneficiaries in the Tenth Circuit

The most direct consequence of Lancaster is that Medicaid applicants and beneficiaries in the Tenth Circuit (Colorado, Kansas, New Mexico, Oklahoma, Utah, Wyoming, and overlapping Indian Country) can no longer bring § 1983 suits alleging violations of:

• Medicaid’s “reasonable promptness” requirement, § 1396a(a)(8), or
• the corollary obligation to give all individuals an opportunity to apply for assistance under the plan.

For claims framed solely as “The State did not furnish assistance with reasonable promptness as required by § 1396a(a)(8),” § 1983 is now unavailable.

This does not necessarily mean that individuals have no recourse:

• States often have internal administrative appeal processes for eligibility and timeliness disputes.
• Some state laws or constitutions may themselves create rights or remedies concerning benefits administration.
• In some circumstances, other federal theories (for example, due process claims) may be available, though those typically require showing a property interest defined by law plus deprivation without adequate process, and Lancaster does not address that terrain.

But the historically important federal avenue—suing state officials directly in federal court under § 1983 for failure to administer Medicaid promptly—has been cut off in the Tenth Circuit.

2. Effects on State Medicaid Agencies

From the perspective of state agencies:

• Reduced exposure to private litigation. Agencies are less likely to face federal § 1983 suits alleging generalized violations of timeliness standards under § 1396a(a)(8). This may reduce litigation risk and associated costs.
• Greater reliance on federal enforcement. The primary enforcer of state compliance with § 1396a(a) conditions remains the federal government—specifically, the Secretary of Health and Human Services, who can withhold or terminate funds under § 1396c in cases of substantial noncompliance.
• Practical accountability dynamics change. In practice, federal administrative enforcement tends to be slower, systemic, and politically mediated, whereas private suits can be faster and sharply focused on individual harms. Removing § 1983 suits shifts the incentives and mechanisms by which agencies are held accountable.

3. Broader Doctrinal Significance Beyond Medicaid

Lancaster is also significant as an example of how lower courts will reread older circuit precedents and Supreme Court dicta after Medina:

• Explicit sidelining of Wright, Wilder, Blessing. The Tenth Circuit takes seriously Medina’s instruction that lower courts should “resist the impulse” to rely on Wright, Wilder, and Blessing when deciding whether Spending Clause statutes create privately enforceable rights. This signals that many existing lower‑court decisions premised on those frameworks (not just in Medicaid, but across the Social Security Act and other grant programs) are now vulnerable.
• Limitations on Title XIX private enforcement. Medicaid is Title XIX of the Social Security Act. Over decades, federal courts had recognized private § 1983 actions to enforce various Medicaid provisions, including reasonable promptness, comparability, and other conditions. Lancaster, tracking Medina, suggests a much narrower universe of potentially enforceable provisions—likely only those that unmistakably use rights‑creating language directed to individuals.
• Tension with Talevski (but not contradiction). Talevski confirmed that Spending Clause statutes can, in principle, confer rights enforceable under § 1983—rejecting the idea of a categorical bar. But Medina and Lancaster reemphasize that such provisions are “atypical.” The presumption is now strongly against finding private rights unless Congress speaks with unusual clarity.

The cumulative effect is a significant constriction of private enforcement of federal conditions in Spending Clause programs.

4. Potential for Future Supreme Court or Legislative Action

Lancaster also sets the stage for possible future developments:

• Further Supreme Court clarification. If other circuits continue to treat § 1396a(a)(8) or similar provisions as privately enforceable, or if they interpret Medina differently, a circuit split could prompt further Supreme Court review. At the time of Lancaster, the Third Circuit’s Sabree stands in some tension with the Tenth Circuit’s view, though Medina may push other circuits to revisit their precedents.
• Congressional response. If Congress wishes to restore (or newly create) private enforcement rights for Medicaid beneficiaries, it can amend the statute to include unequivocal rights‑creating language (e.g., “A Medicaid‑eligible individual shall have a federal right to … and may enforce that right in a civil action …”). Absent such clarifying language, courts applying Medina and Lancaster will remain reluctant to infer private rights under § 1983.

V. Complex Concepts Simplified

A. What Is a “Private Right of Action”?

A private right of action means the law allows a private person (like a Medicaid applicant) to:

1. claim they personally have a legal “right” under a statute; and
2. file a lawsuit to enforce that right and obtain a remedy (such as an injunction or damages).

Section 1983 supplies a general private right of action, but only for “rights” that exist somewhere else (in the Constitution or in a federal statute). The key questions in cases like Lancaster are:

• Does the statute create a “right,” or just a regulatory standard or condition?
• If it creates a right, has Congress given any indication that this right can be enforced through § 1983?

B. Spending Clause Statutes as “Contracts”

Spending Clause statutes, like Medicaid, are often described as operating “like contracts” because:

• Congress offers money to States;
• States agree to certain conditions to receive the money; and
• both sides are understood to be “parties” to this arrangement.

In a normal contract, if Party A breaches, Party B may withhold performance or seek damages. Here:

• the federal government can withhold or terminate funds if a State breaches the conditions; but
• third‑party beneficiaries (like individuals who benefit from the program) do not automatically have the right to sue unless the “contract” clearly gives them that ability.

Medina and Lancaster occupy this space. They say: unless the statute clearly tells States that they may be sued by private individuals for not meeting the conditions, courts should not infer such enforcement rights.

C. “Rights‑Creating Terms” and “Unmistakable Focus”

Medina requires two main things from a statute to find an enforceable right:

1. Rights‑creating terms. The statute should speak in terms of what individuals are entitled to—language like “no person shall be denied,” or “an individual shall have the right to,” rather than only stating what a “State plan must” include.
2. Unmistakable focus on individuals like the plaintiff. The text must show that Congress was not just regulating how States behave towards the federal government, but was directly protecting specific individuals in a way that was meant to be judicially enforceable.

Section 1396a(a)(8) mentions “all individuals wishing to make application” and “all eligible individuals,” but Lancaster—following Medina—reads those references as part of the conditions States must meet in their dealings with the federal government (in order to keep funding), not as explicit conferrals of rights to individuals to sue.

D. “Summary Disposition” and “Supervening Change in Law”

A motion for summary disposition (under FRAP 27 and Tenth Circuit Rule 27.3) asks a court of appeals to decide a case quickly without full briefing or oral argument. One common ground is a “supervening change in law”—for example, when the Supreme Court announces a new rule that clearly controls the outcome of a pending case.

Here:

• the agencies argued that Medina was such a change: it undercut the legal foundation of the Lancasters’ § 1983 claim;
• the Tenth Circuit declined to summarily dispose of the case but ultimately applied Medina in the full opinion to reach the same bottom‑line result.

E. “Bona Fide Loan” and “Countable Resource” (Background Only)

Although Lancaster did not ultimately resolve the case on financial‑eligibility grounds, the background concepts are important in Medicaid practice:

• Countable resource. Medicaid eligibility for long‑term care is limited to individuals whose “resources” (assets) are below certain thresholds. If a person transfers assets but retains a genuine debt owed back to them (a bona fide loan), that debt may be treated differently from a direct ownership interest.
• Bona fide loan. Under POMS SI § 1120.220(B)(3), a loan is bona fide if it is legally enforceable under state law and entered into in good faith, with a real expectation of repayment. Sham loans or transfers primarily designed to qualify for Medicaid can be treated as if the assets were never really given up.

In this case, Oklahoma agencies concluded that the promissory note from the family LLC was not bona fide, so its value counted as a resource. The Tenth Circuit did not need to decide whether that determination was correct because it held there was no enforceable federal right under § 1396a(a)(8) in the first place.

VI. Conclusion

Lancaster v. Cartmell is a landmark case in the Tenth Circuit’s Medicaid jurisprudence—not because it decides anything novel about eligibility rules or asset transfers, but because it declares that Medicaid’s “reasonable promptness” provision, 42 U.S.C. § 1396a(a)(8), does not create a privately enforceable right under § 1983.

Relying on the Supreme Court’s decision in Medina v. Planned Parenthood South Atlantic, the Tenth Circuit:

• adopts a stringent standard for identifying rights under Spending Clause statutes;
• treats rights‑creating provisions as rare exceptions, particularly in Medicaid’s state‑plan “Contents” section;
• rejects reliance on the earlier, more expansive approaches of Wright, Wilder, and Blessing; and
• specifically declines to follow the Third Circuit’s decision in Sabree v. Richman as inconsistent with Medina.

The practical upshot is that Medicaid applicants and beneficiaries in the Tenth Circuit cannot use § 1983 to enforce the federal “reasonable promptness” requirement against state agencies. Instead, compliance with § 1396a(a)(8) is now largely a matter for federal oversight and state‑level processes, unless and until Congress speaks more clearly to create judicially enforceable individual rights.

In the broader legal landscape, Lancaster exemplifies how Medina is reshaping the law of private enforcement under Spending Clause programs, narrowing the scope of § 1983 and compelling lower courts to reevaluate decades of precedent that once allowed beneficiaries to sue directly to enforce federal funding conditions.