476 U.S. 610 (1986) (Supreme Court of the United States)
American Hospital Association v. Bowen—more commonly styled at the Supreme Court as Bowen v.
Does Section 504 of the Rehabilitation Act authorize HHS to promulgate and enforce regulations that treat hospitals' medical treatment decisions for handicapped newborns as discrimination and to require notice, reporting, and investigatory mechanisms aimed at policing such decisions?
Section 504 of the Rehabilitation Act prohibits discrimination 'solely by reason of' handicap against an 'otherwise qualified' individual under any program or activity receiving federal financial assistance. Agencies may issue regulations to effectuate Section 504's anti-discrimination mandate, but they may not expand the statute to impose substantive standards that transform professional decision-making (such as medical treatment judgments) into discrimination analysis where the handicap is an integral, medically relevant factor. Under administrative law principles (including Chevron), courts do not defer to an agency interpretation that is contrary to the statute's text, structure, or purpose, or that intrudes into areas Congress has addressed through other, more specific legislation.
No. HHS exceeded its authority under Section 504. The statute does not empower the agency to regulate the substance of medical treatment decisions for handicapped newborns through anti-discrimination rules or to impose the associated notice, complaint, and enforcement mechanisms aimed at such decisions.
For administrative law students, the case is a clear reminder that Chevron deference has limits: agencies cannot leverage anti-discrimination statutes to impose substantive professional standards untethered to the statute's text and design. For disability and health law, it draws a principled line between discrimination (denying access because of disability) and medical judgments in which disability is medically relevant. The decision also illustrates Congress's role in tailoring solutions—here, shifting the infant-neglect problem to the Child Abuse Amendments—when a general civil rights statute is ill-suited to address specialized medical dilemmas.