2025 has been a rough year for Planned Parenthood. In February, the New York Times ran an exposé about the financial instability and medical negligence in Planned Parenthood clinics across the country. In June in Medina v. Planned Parenthood South Atlantic, the Supreme Court held that Planned Parenthood may not bring a lawsuit in federal court to challenge South Carolina’s decision to cut off state Medicaid funds for two Planned Parenthood clinics. In July, President Trump signed into law the One Big Beautiful Bill’s broad prohibition on using federal Medicaid funds for abortion clinics, including Planned Parenthood, for a one-year period. In September, the First Circuit allowed the One Big Beautiful Bill’s defunding provision to go back into effect after a district court had blocked it.
The year is not yet over, and Planned Parenthood is facing another defunding challenge: a False Claims Act lawsuit in United States ex rel. Doe v. Planned Parenthood Federation of America, Inc. As March for Life President Jennie Bradley Lichter recently described, this “is likely the most important case you’ve never heard of.” Between repayments of the Medicaid funds and penalties for each false claim, Planned Parenthood potentially could be on the hook for over $1.8 billion in this case.
The Impact of Pro-Life Undercover Journalism
After undercover journalism in 2015 showed Planned Parenthood affiliates allegedly selling human fetal tissue in violation of federal law, Louisiana and Texas terminated Planned Parenthood from their Medicaid programs. The Planned Parenthood affiliates did not pursue a state administrative appeal, but, instead, filed lawsuits in federal courts in Louisiana and Texas. In 2020, the en banc Fifth Circuit vacated the preliminary injunction in the Texas case and reversed the Louisiana case since Planned Parenthood could not bring this type of lawsuit in federal court. Later, the Supreme Court came to the same conclusion in Medina: Planned Parenthood may not challenge a state’s decision to terminate the abortion business as a Medicaid provider in federal court.
Planned Parenthood Continues to Bill Medicaid
During this litigation, Planned Parenthood affiliates continued to bill the Texas and Louisiana Medicaid programs for reimbursements even though they were terminated as Medicaid providers. United States ex rel. Doe asks that Planned Parenthood repay these funds and be penalized for their alleged fraudulent claims.
The case is currently on appeal before an en banc Fifth Circuit on a question about whether attorney immunity doctrine prevents Planned Parenthood Federation of America from being liable in this case. The court heard oral arguments in late September and will issue a decision in the coming months before sending the case back to the district court.
United States ex rel. Doe is a part of the greater fight over abortion funding restrictions, which are a cornerstone of pro-life policy. Limitations on the subsidization of abortion clinics ensure funds are not redirected into elective abortion, but, instead, may support authentic women’s healthcare.
