Justia Civil Rights Opinion Summaries

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

Three corporations, each of which owned a nursing home facility, requested a hearing with the Kansas Department on Aging, challenging new reimbursement rates for each facility, arguing that because the facilities underwent a change of ownership, the rates should be recalculated. The hearing officer rejected the corporations' arguments, finding that, by operation of law for Medicaid reimbursement purposes, there was no change of ownership. The Kansas Health Policy Authority upheld the ruling, and the district court affirmed. The Supreme Court affirmed, holding that the agency orders were valid, did not violate equal protection or due process, and were not vague. View "Village Villa v. Kan. Health Policy Auth." on Justia Law

In the four cases giving rise to these eleven consolidated appeals, the Secretary of the Department of Health and Human Services (HHS) and the Director of the California Department of Health Care Services (DHCS), appealed the district court's grant of preliminary injunctions to plaintiffs, various providers and beneficiaries of California's Medicaid program (Medi-Cal). At issue was the implementation of Medi-Cal reimbursement rate reductions. The court held that Orthopaedic Hospital v. Belshe did not control the outcome in these cases because it did not consider the key issue here - the Secretary's interpretation of 42 U.S.C. 1396a(a)(30)(A); the Secretary's approval of California's requested reimbursement rates were entitled to Chevron deference; and the Secretary's approval complied with the Administrative Procedures Act, 5 U.S.C. 500 et seq. The court further held that plaintiffs were unlikely to succeed on the merits on their Supremacy Clause claims against the Director because the Secretary had reasonably determined that the State's reimbursement rates complied with section 30(A). The court finally held that none of the plaintiffs had a viable takings claim because Medicaid, as a voluntary program, did not create property rights. View "Managed Pharmacy Care, et al v. Sebelius, et al" on Justia Law

Applicant Marilyn Clifford appealed the denial of long-term home-care benefits under the Medicaid-funded Choices for Care program, arguing that a second home on an adjacent piece of property should have been excluded from the financial-eligibility calculation. Given the language of the regulation, the legislative history that led to its promulgation, and the policy considerations attending the Medicaid program, the Supreme Court concluded that the Secretary correctly interpreted the home-exclusion rule when he reinstated the determination of the Department of Children and Families denying the benefits. Thus, the Court found no compelling indication of error in the Secretary’s determination and affirmed. View "In re Marilyn Clifford" on Justia Law

Appellant was a personal care attendant for a Medicaid beneficiary. Appellant was later charged with Medicaid fraud for submitting a false claim for his services. After a bench trial Appellant was convicted under Kan. Stat. Ann. 21-3846(a)(1) for defrauding the Medicaid program. The court of appeals reversed Appellant's conviction, holding that the complaint charged that Appellant submitted statements for services he did not provide while the evidence at trial established that Appellant actually did provide the services for which he submitted statements. The Supreme Court reversed the court of appeals and affirmed the district court, holding that sufficient evidence supported Appellant's conviction for Medicaid fraud.