Bowen v. Massachusetts

In Bowen v. Massachusetts, 487 U.S. 879, 901, 108 S.Ct. 2722, 101 L.Ed.2d 749 (1988), the Supreme Court addressed the meaning of "adequate remedy" under 704 of the Administrative Procedure Act (APA). While observing that 704 was not intended to provide additional judicial remedies "where the Congress has provided special and adequate review procedures," the Court explained that "the exception that was intended to avoid such duplication should not be construed to defeat the central purpose of providing a broad spectrum of judicial review of agency action." Id. at 903-04, 108 S.Ct. 2722. In that case, the Court concluded that relief in the Claims Court "is plainly not the kind of `special and adequate review procedure' that will oust a district court of its normal jurisdiction under the APA." Id. at 904, 108 S.Ct. 2722. Not only was reviewability of a disallowance decision by the Claims Court "doubtful," the Claims Court lacked equitable jurisdiction to grant prospective relief, which the Court considered appropriate in light of the interaction between the states' administration of an approved Medicaid plan and the HHS Secretary's regulatory interpretation. Id. at 905, 108 S.Ct. 2722. The Court was unwilling to assume a money judgment "will always be an adequate substitute for prospective relief...." Id.