Justia Civil Rights Opinion Summaries

This dispute arose from California's implementation of a change to Medicare in 2006. The Centers argued that California mishandled the shift in payment responsibility for dual-eligibles' prescription drug costs from state Medicaid programs to the new, federal Medicare Part D Program. The Centers brought suit for declaratory and injunctive relief. Among other things, the Centers urged the federal courts to declare unlawful California's "seizure" of the Centers' Medicare Part D funds, in excess of what would be owed under the per-visit rate for the Centers' expenses. The court concluded that the Eleventh Amendment barred the Centers' claims for retroactive monetary relief; the court affirmed the district court's dismissal of the Centers' claims to the extent that they sought money damages; however, the court reversed the district court and remanded to allow the district court to assess Ex parte Young's application to the Center's remaining claims. View "North East Medical Services v. CA Dept. of Health" on Justia Law

In 1979, Plaintiffs sued under 42 U.S.C. 1983, on behalf of present and future recipients, alleging that Tennessee’s Medicaid program violated federal requirements, 42 U.S.C. 1396, and the Due Process Clause. The decades that followed involved intervenors, consent orders, revisions, and creation of a subclass. In 1994, Tennessee converted to a managed care program, TennCare. In 1995, five class members filed motions alleging that TennCare was being administered inconsistent with a 1992 decree and federal law. In 2009, the district court awarded plaintiffs more than$2.57 million for fees and expenses leading up to a 2005 Revised Consent Decree. Plaintiffs had originally requested a lodestar amount of $3,313,458.00, but the court reduced the award by 20 percent on account of plaintiffs’ “limited” success relative to the breadth of defendants’ requests and the scope of the litigation. The court noted that there was “no dispute that Plaintiffs in this case are the prevailing party, and thus entitled to attorneys’ fees under 42 U.S.C. 1988.” The Sixth Circuit vacated parts of the award, noting that section 1988 “is not for the purpose of aiding lawyers and that the original petition for fees included requests for dry cleaning bills, mini blinds, and health insurance. View "Binta B. v. Gordon" on Justia Law

Appellant was a fifty-five-year-old male with a history of schizoaffective disorder. The State filed a petition to involuntarily commit Appellant, alleging that Appellant was unable to care for his basic needs and appeared to pose a danger to himself and others. After a hearing, the district court granted the State's petition and involuntarily committed Appellant to the Montana State Hospital (MSH), authorizing MSH to administer appropriate medication involuntarily. The Supreme Court affirmed, holding (1) the district court did not violate Appellant's statutory and due process rights when it failed to obtain a personal waiver of rights under Mont. Code Ann. 53-21-119(1), as Appellant effectively waived his rights by allowing his counsel to inform the judge of his desire to do so; and (2) the district court complied with the statutory requirements in ordering Appellant to take medications as prescribed by his doctors, and this directive was sufficient to authorize involuntary medication. View "In re R.W.K." on Justia Law

Plaintiffs, thirteenth North Carolina residents who lost access to in-home personal care services (PCS) due to a statutory change, brought suit challenging the new PCS program. The district court granted plaintiffs' motions for a preliminary injunction and class certification. Defendants appealed, raising several points of error. The court agreed with the district court's conclusion that a preliminary injunction was appropriate in this case. The court held, however, that the district court's order failed to comply with Federal Rule of Civil Procedure 65 because it lacked specificity and because the district court neglected to address the issue of security. Accordingly, the court remanded the case. View "Pashby v. Delia" on Justia Law

Hudson filed suit in an Illinois district court under the Federal Tort Claims Act, charging that medical personnel at a federal prison in Kansas, where he had been incarcerated, had negligently failed to diagnose a blood clot in his leg and that, as a result, he experienced serious health problems. The government moved to transfer the case to the federal district court in Kansas pursuant to 28 U.S.C. 1404(a), on the ground that the principal witnesses are in Kansas and that the Kansas court has a lighter caseload. The district court granted the motion. Hudson has petitioned the Seventh Circuit, arguing that the case should remain in Illinois because he lives here, as do his current treating physicians, who will testify about his current health problems and causation. His Illinois relatives will also testify to his continuing health problems. The Seventh Circuit dismissed, noting that about two-thirds of the witnesses are closer to Kansas, that the medical records are in Kansas, and the ease of electronic communications. View "Hudson v. Baker" on Justia Law

The Association sued the County, alleging that the County had breached its obligation to provide certain vested healthcare benefits in perpetuity. The Association alleged that the County had implicitly promised to provide these benefits. The California Supreme Court's recent decision in Retired Employees Ass'n of Orange County, Inc. v. County of Orange (REAOC II) recognized that a county could form a contract with implied terms under specified circumstances. The court held that the district court did not err in concluding that the amended complaint failed to state a cause of action. Nevertheless, in light of REAOC II, the court could not agree with the district court's decision to deny the Association leave to amend on the ground that such amendment would be futile. Accordingly, the court vacated and remanded for further proceedings consistent with REAOC II. View "Sonoma Cnty. Ass'n of Retired Emp. v. Sonoma Cnty." on Justia Law

Respondent Robert Chaney was fired from his position and argued his termination violated the federal Family and Medical Leave Act of 1993 (FMLA). The employer, Providence Health Care d/b/a Sacred Heart Medical Center & Children's Hospital (Providence), claimed no violation of the FMLA occurred. The trial court denied motions for a directed verdict on the issue by both Chaney and Providence. Based upon undisputed facts, the Supreme Court held that the trial court erred in failing to grant Chaney's motion for a directed verdict that as a matter of law the hospital violated the FMLA. In 2005, his wife fell ill after giving birth, Chaney himself suffered a back injury, and he relied heavily on FMLA leave over the next two years. By June 2007, Chaney had used up most of his FMLA leave and had been donated leave from other employees. The record indicated that Providence administration and other staff were growing resentful that Chaney had taken so much time off. In 2007, an employee reported that Chaney appeared fatigued and incoherent. Although no claim was made that his work was compromised, Chaney was ordered to report for drug testing. The drug test was positive for methadone. Chaney had a prescription for methadone to treat back pain, but the doctor who gave the drug test noted that Chaney "[m]ay need fitness for duty evaluation or visit to his Dr. to fine tune his medication." A few months later, Chaney indicated he was prepared to return to work. The record reflected that Chaney was erroneously informed he needed Providence's permission to return to work. This violated the FMLA, under which Chaney could only be required to get authorization from his own health care provider. Chaney went to Providence's doctor, and administration told him the hospital would not allow him to return to work unless their doctor changed his recommended restriction. The hospital's doctor refused to change his recommendation. Subsequently, Chaney was fired. Providence claimed the termination was proper because Chaney failed to provide a valid fitness for work certification as required under the FMLA. View "Chaney v. Providence Health Care" on Justia Law

Quigley was 23 years old, with no known life-threatening physical conditions when he was transferred from one Michigan Department of Corrections (MDOC) facility to an MDOC guidance center, where he was under the care of CMS, a service provider with which MDOC contracted. CMS employees Dr. Thai and physician’s assistant Garver treated Quigley for moderate depression and prescribed medications. After about a month, Quigley was found dead in his cell. The medication chart confirmed that Quigley had been administered both Amitriptyline and Trazodone the previous three days. The autopsy report concluded that Quigley died of an epileptic seizure disorder. Quigley’s estate obtained affidavits from a forensic pathologist, who concluded that Quigley likely died from a fatal drug interaction between the tricyclic Amitriptyline and tetracyclic Trazodone and from a psychiatrist, who similarly concluded that the fatal drug interaction likely killed Quigley. Thai provided three medical-expert affidavits, all concluding that the best explanation for Quigley’s death is epileptic seizure. Quigley’s estate sued Thai, Garver, and CMS under 42 U.S.C. 1983. The district court denied a motion asserting qualified immunity. The Sixth Circuit affirmed, finding that there were unresolved material questions of fact concerning the cause of death. View "Quigley v. Thai" on Justia Law

After Respondent voluntarily admitted herself to the behavioral health unit of a hospital, Respondent requested to be discharged. However, the county attorney's office filed a petition requesting that Respondent be committed for further evaluation and treatment. The district court appointed a public defender to represent Respondent, and following a hearing on the petition for commitment, the court committed Respondent to the Montana State Hospital with a treatment order that included the involuntary administration of medication. The Supreme Court affirmed, holding (1) plaint error review of this issue was not warranted; and (2) Respondent was not denied the effective assistance of counsel during the hearing. View "In re J.S.W." on Justia Law

Since 2006 Ray has experienced pain in his shoulder. He contends that the pain stems from an injury and that an MRI scan would point the way toward successful treatment; Shah, Ray’s treating physician at the correctional center, believes that the pain stems from arthritis and that a scan would not help in diagnosis and treatment. The district court rejected Ray’s suit under 42 U.S.C.1983. The Seventh Circuit affirmed, noting that Ray has been examined often, x-rays have been taken, and physicians have prescribed painkillers; staff also has arranged for Ray to be assigned a lower bunk. Because Ray’s claim fails the objective component of cruel-and-unusual-punishments analysis, his contention that Dr. Shah displayed subjective antipathy is irrelevant. View "Ray v. Wexford Health Sources, Inc." on Justia Law