Justia Civil Rights Opinion Summaries

Provider Plaintiffs and Individual Plaintiffs filed suit seeking a preliminary injunction against the OIG's decision to terminate the Medicaid provider agreements to Planned Parenthood affiliates throughout the state. The district court held that the Individual Plaintiffs possessed a private right of action under the "qualified-provider" provision of the Medicaid Act and issued a preliminary injunction.The Fifth Circuit held that the district court erred in evaluating the evidence de novo, rather than under the arbitrary and capricious standard, and in applying the reasoning in Planned Parenthood Gulf Coast v. Gee, 862 F.3d 445 (5th Cir. 2017), to its determination of a "qualified" provider in this context. Therefore, the district court erred legally and plaintiffs were unlikely to show a likelihood of success on the merits of their claim. Accordingly, the court vacated the preliminary injunction and remanded for the district court to limit its review to the agency record under an arbitrary-and-capricious standard. View "Planned Parenthood of Greater Texas Family Planning and Preventative Health Services v. Smith" on Justia Law

After federal agencies issued two interim final rules (IFRs) exempting employers with religious and moral objections from the Affordable Care Act requirement that group health plans cover contraceptive care without cost sharing, states filed suit to enjoin the enforcement of the IFRs. The Ninth Circuit affirmed that venue was proper in the Northern District of California; affirmed that plaintiff states have standing to sue based on procedural injury where the states have shown with reasonable probability that the IFRs will first lead to women losing employer-sponsored contraceptive coverage, which will then result in economic harm to the states; affirmed the preliminary injunction insofar as it barred enforcement of the IFRs in the plaintiff states; but vacated the portion of the injunction barring enforcement in other states because the scope of the injunction was overbroad. View "California v. Azar" on Justia Law

The Supreme Court affirmed in part and reversed in part the district court’s dismissal of Plaintiff’s complaint alleging negligence and violations of 42 U.S.C. 1983 after Linda Gelok was injured after being left unattended for twenty-five hours at the Wyoming State Hospital (WSH), holding that the complaint alleged sufficient facts to state a claim for relief under 42 U.S. C. 1983 against Paul Mullenax, WSH Administrator, in his individual capacity.On behalf of Linda Gelok, an involuntarily committed incompetent person, Plaintiff sued the WSH, the Wyoming Department of Health, and Mullenax, WSH Administrator, in his official and individual capacities, alleging negligence and violation of her constitutional rights under 42 U.S.C. 1983. The district court dismissed the negligence action as time-barred. As to the constitutional claims, the district court found that the WSH, the Department, and Mullenax in his official capacity were entitled to Eleventh Amendment immunity and that Mullenax was entitled to qualified immunity in his individual capacity. The Supreme Court held (1) Wyo. Stat. Ann. 1-3-107 barred Plaintiff’s negligent health care claim; (2) the district court properly dismissed Plaintiff’s 42 U.S.C. 1983 claims against most defendants; but (3) Plaintiff’s complaint alleged sufficient facts to state a claim for relief under 42 U.S.C. 1983 against Mullenax in his individual capacity. View "Wyoming Guardianship Corp. v. Wyoming State Hospital" on Justia Law

This appeal presented a question of whether established law supported Plaintiff Joseph Leiser's claim that two jail officials in Coffey County, Kansas, violated his constitutional rights by disclosing medical information about him that they had properly obtained. Plaintiff was set to be extradited from Illinois to Kansas, and the Kansas jail requested Illinois arrange for multiple medical examinations of Plaintiff to determine whether he had suffered injuries after being tasered by U.S. Marshals. The Kansas official learned Plaintiff had bone lesions and possibly cancer. This information was conveyed to the Coffey County Sheriff, who conveyed it to Coffey County Hospital, then to Plaintiff's family and friends, without first obtaining Plaintiff's permission. The Tenth Circuit determined the prison officials were entitled to qualified immunity, and dismissed his case. View "Leiser v. Moore" on Justia Law

The Court of Appeal affirmed the trial court's order dismissing plaintiffs' challenge to an amendment to California law that eliminated the previously existing "personal beliefs" exemption from mandatory immunization requirements for school children. Senate Bill No. 277 eliminated the personal beliefs exemption from the requirement that children receive vaccines for specified infectious diseases before being admitted to any public or private elementary or secondary school, day care center or the like. The court held that plaintiffs failed to cite any authority for their assertion that SB 277 violated freedom of religion and plaintiffs' free exercise claim was meritless; SB 277 did not violate plaintiffs' constitutional right to attend school; SB 277 did not violate the equal protection clause where the statutory classifications and exemptions plaintiffs disputed did not involve similarly situated children, or were otherwise entirely rational classifications; SB 277 was not void for vagueness where it was sufficiently clear to give fair warning of the required conduct; and SB 277 did not violate Health and Safety Code 24175 subdivision (a). View "Brown v. Smith" on Justia Law

Montana’s Preferred Provider Agreements Act (MPPAA), Mont. Code Ann. 33-22-1701 to -1707, does not violate the Equal Protection Clause of the Montana Constitution.Plaintiff sought and received treatment from St. Peter’s Hospital for various injuries and symptoms. Because Plaintiff did not have health insurance the Hospital billed Plaintiff directly, but almost all of Plaintiff’s treatments costs were either covered by another party’s insurance or significantly discounted by the Hospital’s financial-need discount. Plaintiff brought this lawsuit arguing that the statutes authorizing the Hospital’s billing practices violate the Equal Protection Clause of the Montana Constitution. The district court concluded that the MPPAA creates similarly situated classes but does not violate Plaintiff’s equal protection rights. The Supreme Court affirmed, holding that the MPPAA, which authorizes the Hospital’s billing practices, does not deprive Plaintiff of her right to equal protection. View "Gazelka v. St. Peter's Hospital" on Justia Law

The Ninth Circuit affirmed the district court's grant of summary judgment for the Department in an action brought by private ambulance companies challenging the reimbursement rate for their transportation of patients covered by Medi-Cal. The panel held that plaintiffs failed to carry their burden of producing evidence upon which a reasonable jury could return a verdict in their favor and thus the district court did not err in entering judgment in the Department's favor on the Takings Clause claim. The panel reasoned that the ambulance companies lacked a constitutionally protected property interest in a particular reimbursement rate, but the mandatory-care provision of Cal. Health & Safety Code 1317(d) implicated a constitutionally protected property right. The panel held that section 1317(d) did not effect a regulatory taking under the Penn Central test. The panel also held that the ambulance companies did not establish a due process claim regarding DHCS's failure to ensure that Medi-Cal reimbursement rates kept pace with their costs because they lacked a constitutionally protected interest in any particular reimbursement rate. View "Sierra Medical Services Alliance v. Kent" on Justia Law

In 2016, Kansas sent notices of decisions to terminate its Medicaid contracts with two Planned Parenthood affiliates, Planned Parenthood of Kansas and Mid-Missouri (“PPGP”), and Planned Parenthood of the St. Louis Region (“PPSLR”). The notices cited concerns about the level of PPGP’s cooperation in solid-waste inspections, both Providers’ billing practices, and an anti-abortion group’s allegations that Planned Parenthood of America (“PPFA”) executives had been video-recorded negotiating the sale of fetal tissue and body parts. Together, the Providers and three individual Jane Does (“the Patients”) immediately sued Susan Mosier, Secretary of the Kansas Department of Health and Environment (“KDHE”), under 42 U.S.C. 1983, alleging violations of 42 U.S.C. 1396a(a)(23) and the Equal Protection Clause of the Fourteenth Amendment. The Plaintiffs sought a preliminary injunction enjoining Kansas from terminating the Providers from the state’s Medicaid program. "States may not terminate providers from their Medicaid program for any reason they see fit, especially when that reason is unrelated to the provider’s competence and the quality of the healthcare it provides." The Tenth Circuit joined four of five circuits that addressed this same provision and affirmed the district court’s injunction prohibiting Kansas from terminating its Medicaid contract with PPGP. But the Court vacated the district court’s injunction as it pertained to PPSLR, remanding for further proceedings on that issue, because Plaintiffs failed to establish standing to challenge that termination. But on this record, the Court could not determine whether PPSLR itself could establish standing, an issue the district court declined to decide but now must decide on remand. View "Planned Parenthood v. Andersen" on Justia Law

After complaints about his professionalism, Indiana University Hospital required Dr. Hamdan, a U.S. citizen of Palestinian descent, to participate in a peer-review process, which resulted in disciplinary letters. Hamdan successfully appealed. The hospital ultimately voided the letters. Nonetheless, Hamdan resigned and relinquished his hospital privileges. Hamdan sued the hospital for discriminating against him based on race. Hamdan was not a hospital employee and could not sue under Title VII, so he sued under 42 U.S.C. 1981, part of the Civil Rights Act of 1866, intended to protect the ability of newly-freed slaves to enter and enforce contracts. Hamdan alleged discrimination in his contractual relationship with the hospital. The Seventh Circuit affirmed a verdict for the hospital, rejecting an argument that the district court erred in allowing the hospital to ask Hamdan impeachment questions relating to his prior work at other hospitals. The court noted Hamdan’s testimony that his reputation was “untarnished” before he received the disciplinary letters. The Seventh Circuit also rejected an argument that the court erred in permitting the hospital to try to impeach him with questions about matters that were confidential under the peer-review statutes of Indiana, Louisiana, and Michigan. Even if the state laws applied, the judge did not abuse his discretion in allowing impeachment questions about incident reports. View "Hamdan v. Indiana University Health North Hospital, Inc." on Justia Law

Nevada’s medical marijuana registry does not violate the Due Process, Equal Protection, or Self-Incrimination Clauses of the United States or Nevada Constitutions.Appellant in this case applied for and received a registry identification card. Thereafter, Appellant filed suit against the Nevada Legislature, the Governor, and the Department of Health and Human Services (collectively, Respondents) arguing that the medical marijuana registry and its associated fees violated his due process and equal protection rights and his right against self-incrimination. The district court granted summary judgment for Respondents. The Supreme Court affirmed, holding (1) Nevada’s medical marijuana registry does not impinge upon a fundamental right; (2) the registry is rationally related to the legitimate state interest of protecting the health, safety, and welfare of the public; and (3) the registry does not violate a registrant’s right against self-incrimination. View "Doe v. State ex rel. Legislature of 77th Session" on Justia Law