Page:Health and Hospital Corp. of Marion Co. v. Talevski.pdf/18

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HEALTH AND HOSPITAL CORPORATION OF MARION CTY. v. TALEVSKI

Opinion of the Court

Gonzaga sets forth our established method for ascertaining unambiguous conferral. Courts must employ traditional tools of statutory construction to assess whether Congress has “unambiguously conferred” “individual rights upon a class of beneficiaries” to which the plaintiff belongs. Id., at 283, 285–286; see also Rancho Palos Verdes v. Abrams, 544 U. S. 113, 120 (2005). Notably, it must be determined that “Congress intended to create a federal right” for the identified class, not merely that the plaintiffs fall “within the general zone of interest that the statute is intended to protect.” Gonzaga, 536 U. S., at 283 (emphasis deleted). This paradigm respects Congress’s primacy in this arena and thus vindicates the separation of powers. Id., at 286.

We have held that the Gonzaga test is satisfied where the provision in question is “ ‘phrased in terms of the persons benefited’ ” and contains “rights-creating,” individual-centric language with an “ ‘unmistakable focus on the benefited class.’ ” Id., at 284, 287 (emphasis deleted). Conversely, we have rejected §1983 enforceability where the statutory provision “contain[ed] no rights-creating language”; had “an aggregate, not individual, focus”; and “serve[d] primarily to direct the [Federal Government’s] distribution of public funds.” Id., at 290.

If a statutory provision surmounts this significant hurdle, it “secure[s]” §1983-enforceable rights, consistent with §1983’s text. And because “§1983 generally supplies a remedy for the vindication of rights secured by federal statutes,” rights so secured are deemed “presumptively enforceable” under §1983. Gonzaga, 536 U. S., at 284.

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The unnecessary-restraint and predischarge-notice provisions meet this test. To start, we note that both reside in 42 U. S. C. §1396r(c), which expressly concerns “[r]equirements relating to residents’ rights.” Ibid. (emphasis added;