Syllabus
Gonzaga sets forth the Court’s 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. 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.” Id., at 283 (emphasis deleted). The test for unambiguous conferral 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). If a statutory provision surmounts this significant hurdle, it “secures” individual rights that are deemed “presumptively enforceable” under §1983. Id., at 284.
The unnecessary-restraint and predischarge-notice provisions in FNHRA that Talevski’s complaint invokes meet this test. The FNHRA lays out a litany of statutory “[r]equirements relating to residents’ rights,” §1396r(c). The unnecessary-restraint provision requires nursing facilities to “protect and promote” residents’ “right to be free from … any physical or chemical restraints … not required to treat the resident’s medical symptoms.” §1396r(c)(1)(A)(ii). The predischarge-notice provision imposes preconditions that a nursing facility must meet to “transfer or discharge [a] resident.” §§1396r(c)(2)(A)–(B). Both provisions reside in §1396r(c), which expressly concerns “[r]equirements relating to residents’ rights.” Ibid. (emphasis added). This framing is indicative of an individual “rights-creating” focus. Gonzaga, 536 U. S., at 284. That these two provisions also establish who must comply with these statutory rights (namely, the Medicaid-participant nursing homes) does not dispel the statute’s focus on the nursing-home residents, i.e., the benefited class. The provisions use clear “rights-creating language,” speak “ ‘in terms of the persons benefited,’ ” and have an “ ‘unmistakable focus on the benefited class.’ ” Id., at 284, 287, 290 (emphasis deleted). Thus, they satisfy Gonzaga’s stringent standard, and the rights they recognize are presumptively enforceable under §1983. Pp. 11–17.
