Justia Civil Rights Opinion Summaries

Plaintiff, a recipient of Supplemental Security Income (SSI) benefits, appealed from the district court's judgment sua sponte dismissing his amended complaint under 28 U.S.C. 1915(e)(2)(B). Plaintiff sought an Order to Show Cause, a temporary restraining order, and a preliminary injunction enjoining defendants from levying against his SSI benefits to enforce a child support order. At issue was whether 42 U.S.C. 659(a) authorized levy against SSI benefits provided under the Social Security Act, 42 U.S.C. 301 et seq., to satisfy the benefits recipient's child support obligations. The court concluded that SSI benefits were not based upon remuneration for employment within the meaning of section 659(a); section 659(a) did not preclude plaintiff's claims; and the Rooker-Feldman doctrine and the exception to federal jurisdiction for divorce matters did not preclude the district court from exercising jurisdiction over the matter. Accordingly, the court vacated the judgment to the extent the district court dismissed plaintiff's claims against the agency defendants and remanded for further proceedings. However, the court affirmed the portion of the judgment dismissing plaintiff's claims against Bank of America because his complaint had not alleged facts establishing that the bank was a state actor for purposes of 42 U.S.C. 1983. View "Sykes v. Bank of America" on Justia Law

After Defendants were charged with Medicaid fraud, the Commonwealth obtained search warrants to obtain and search designated e-mail accounts of Defendants' former billing director. Defendants moved for a protective order, claiming that the attorney-client privilege protected many of the e-mails. A motion judge amended the order to permit the Commonwealth to search the e-mails by using a "taint team," assistant attorneys general not involved in the investigation or prosecution of Defendants. Defendants filed a petition seeking relief from the order. The Supreme Court answered reported questions from the county court by holding (1) the Commonwealth may, by means of an ex parte search warrant, search the post-indictment emails of a criminal defendant; and (2) the "taint team" procedure was permissible under the Massachusetts Constitution. View "Preventive Med. Assocs. v. Commonwealth" on Justia Law

In 2011 Wisconsin reduced subsidies for the Wisconsin Care Program, which funds grants for organizations administering programs for disabled persons who live in group homes. The plaintiffs are developmentally disabled and suffered the largest cuts. Persons who had received smaller payments bore smaller cuts. For some (frail elderly) per capita payments increased. Plaintiffs claim that making larger absolute cuts for persons whose care is most expensive violated the Rehabilitation Act and the Americans with Disabilities Act and that reduction in payments increases the risk that they will be moved from group homes to institutions. The district judge noted that states have waived sovereign immunity with respect to the Rehabilitation Act, as a condition to receiving federal funds. The Supreme Court has held that the portions of the ADA that are not designed to implement disabled persons’ constitutional rights cannot be used to override states’ sovereign immunity. The district court concluded that the relevant provisions of the ADA do not concern the Constitution and that other claims were premature because no plaintiff has been moved to an institution. The Seventh Circuit affirmed, noting that without information about care provided to other disabled persons, there is no useful theory of discrimination. View "Amundson v. WI Dep't of Health Servs." on Justia Law

The Clinics filed suit challenging California Welfare and Institutions Code 14131.10, which eliminated certain Medi-Cal benefits that the state deemed optional, including adult dental, podiatry, optometry, and chiropractic services. The court reversed the district court's holding that the Clinics have a private right of action to challenge the Department's implementation of the state plan amendments (SPA) prior to obtaining approval; affirmed that the Clinics have a private right of action to bring a claim pursuant to 42 U.S.C. 1983 challenging the validity of section 14131.10; and reversed the district court's interpretation of the Medicaid Act, 42 U.S.C. 1396 et seq., holding that section 14131.10 impermissibly eliminated mandatory services from coverage. View "California Ass'n of Rural Health Clinics v. Douglas" on Justia Law

Plaintiff appealed the termination of her Medicaid benefits. At issue was the enforceability of a provision of the Medicaid Act, 42 U.S.C. 1396a(a)(8), under 42 U.S.C. 1983. The court concluded that section 1396a(a)(8) created a right enforceable under section 1983, and that exhaustion of Louisiana's procedure for judicial review was not required before a Medicaid claimant filed suit in federal court. Accordingly, the court affirmed the judgment of the district court denying DHH's motion to dismiss because plaintiff's claims were properly before the district court. View "Romano v. Greenstein" on Justia Law

Plaintiffs appealed the Secretary's denial of their claims for Medicare coverage for dental services. Plaintiffs contended that this denial was premised on the Secretary's unreasonable interpretation of the Medicare Act, Pub. L. No. 89-97, 79 Stat. 286, which contravened the intent of Congress and violated plaintiffs' right to equal protection under the Fifth Amendment. The court concluded that, although the statutory provision for exclusion of dental services was ambiguous in the sense that plausible divergent constructions could be urged, the Secretary's interpretation of the statute was reasonable. The court also concluded that the Secretary's statutory interpretation warranted Chevron deference and the Secretary's statutory interpretation was reasonable. Accordingly, the court affirmed the judgment. View "Fournier v. Sebelius" on Justia Law

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

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

The State appealed from the district court's order enjoining it from requiring plaintiff to submit to a suspicionless drug test pursuant to Section 414.0652 of the Florida Statutes, as a condition for receipt of government-provided monetary assistance for which he was otherwise qualified. Plaintiff applied for financial assistance benefits for himself and his son through Florida's Temporary Assistance for Needy Families program (TANF). The court held that the district court did not abuse its discretion in granting the preliminary injunction enjoining the State from enforcing the statute because the court concluded that the State had failed to establish a substantial special need to support its mandatory suspicionless drug testing of TANF recipients. View "Lebron v. Secretary, FL Dept. of Children and Families" on Justia Law