Justia Civil Rights Opinion Summaries

Applicants for and recipients of Medicaid home health Services claimed that the New York State Office of Temporary and Disability Assistance and the New York State Department of Health, violated their statutory right, enforceable under 42 U.S.C.1983, to an opportunity for Medicaid fair hearings. They claimed that this right, as construed by federal regulation, entitles them to “final administrative action” within 90 days of their fair hearing requests. The district court declared that “final administrative action” includes the holding of Medicaid fair hearings, the issuance of fair hearing decisions, and the implementation of any relief ordered in those decisions and permanently enjoined the state agencies to ensure that “final administrative action” implemented within 90 days of fair hearing requests. The Second Circuit affirmed in part, holding that the plaintiffs have a right to a Medicaid hearing and decision ordinarily within 90 days of their fair hearing requests, and that such right is enforceable under section 1983. The permanent injunction was, however, overbroad because “final administrative action” refers not to the implementation of relief ordered in fair hearing decisions, but to the holding of fair hearings and to the issuance of fair hearing decisions.

Petitioners Leroy and Glenda Morris brought suit under 42 U.S.C. 1983 and the Supremacy Clause to challenge the Oklahoma Department of Human Services' ("OKDHS") denial of Mrs. Morris' application for Medicaid benefits as inconsistent with federal law. After calculating the couple's resources and the Community Spouse Resource Allowance (CSRA), OKDHS determined that the Morrises were ineligible for benefits. In an effort to "spend down" their excess resources, the Morrises purchased an actuarially sound annuity payable to Mr. Morris. Despite this purchase, OKDHS determined that Mrs. Morris remained ineligible. The district court granted summary judgment in favor of OKDHS, upholding the agency's application of the Medicaid statutes. Upon review, the Tenth Circuit reversed and remanded the case for further proceedings. A couple may convert joint resources (which may affect Medicaid eligibility) into income for the community spouse (which does not impact eligibility) by purchasing certain types of annuities. In other words, a couple may purchase a qualifying annuity payable to the community spouse in addition to the community spouse's retention of the CSRA.

Howard Back filed this suit alleging that Secretary of Heath and Human Services Kathleen Sebelius violated her duties under the Medicare Act and the Due Process Clause by failing to provide an administrative process for beneficiaries of hospice care to appeal a hospice provider's refusal to provide a drug prescribed by their attending physician. The district court granted the Secretary's motion for judgment on the pleadings because Back had not exhausted his administrative remedies. The Ninth Circuit Court of Appeals vacated the district court's judgment and dismissed the appeal as moot, holding that although the government led Back to believe there was no appeal process, such a process did exist. Accordingly, no controversy existed and the appeal was moot.

Plaintiffs appealed from the district court's dismissal of their amended complaint against Florida government defendants, SBHD, AHCA, and DCF. Plaintiffs alleged that defendants' billing practice violated both 42 U.S.C. 1396a(a)(25)(C), the "balance billing" provision of the federal Medicaid Act, and a similar Florida statute. The court concluded that section 1396a(a)(25)(C) did not confer upon plaintiffs a federal right enforceable under 42 U.S.C. 1983 and therefore, affirmed the district court's decision to dismiss the amended complaint.

This case began as a dispute over the results of CM's special education evaluation under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. At issue on appeal was: (1) the ALJ's dismissal of several of CM's claims against Lafayette prior to holding a due process hearing; and (2) the district court's dismissal of MM's, CM's parents, separate claims against the California Department of Education (CDE). The court held that the district court correctly dismissed MM's claims against Lafayette challenging the ALJ's statute of limitations ruling as being premature. The district court did not abuse its discretion in dismissing the fourth claim as duplicative and correctly held that the CDE had no authority to oversee the individual decisions of OAH's hearing officers. Accordingly, the court affirmed the judgment of the district court.

T.B.'s parents, on behalf of their autistic child, appealed the district court's finding that the school district did not violate the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., by failing to provide a free appropriate public education (FAPE) to T.B., making the parents ineligible for reimbursement for the costs of T.B.'s home-based program. Given the parents' decision to ultimately settle the issue of the adequacy of the proposed individualized education program (IEP), the court questioned whether they could claim, much less successfully show, that the school district failed to provide a FAPE to T.B. Nonetheless, based on the record, the court could not say that T.B.'s home-based program was "reasonably calculated to enable [him] to receive educational benefits." The program was therefore not "proper" within the meaning of the IDEA and the parents were not entitled to reimbursement for the costs associated with it. Accordingly, the court affirmed the judgment.

Plaintiffs, parents of children who were eligible to receive a free and appropriate public education, filed suit to challenge the exclusion of mapping of cochlear implants from the regulatory definition of "related services" under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1401(26)(B). The court concluded that the phrase "audiology services" as used in the IDEA's "related services" definition did not unambiguously encompass mapping of cochlear implants. The court also found that the Mapping Regulations embodied a permissible construction of the IDEA because they were rationally related to the underlying objectives of the IDEA. The court further found that the Mapping Regulations did not substantially lessen the protections afforded by the 1983 regulations. Because the Department's construction of its own regulation was neither plainly erroneous nor inconsistent with the regulation, the court owed it deference. Accordingly, the court affirmed the district court's grant of summary judgment to the Department.

Plaintiffs, three plaintiff-classes and Sheila Perdue individually, brought a class action complaint seeking declaratory and injunction relief alleging violations of their federal statutory and constitutional rights. Plaintiffs challenged the Indiana Family and Social Services Administration's (FSSA) automated system of processing claims for Medicaid, Food Stamps, and Temporary Assistance to Needy Families benefits. The trial court held (1) the FSSA's denial notices satisfied due process; (2) the FSSA could not deny an application for Food Stamp benefits when the applicant failed to cooperate in the eligibility determination process; and (3) determined that the FSSA had failed to accommodate Perdue's disabilities in violation of the Americans with Disabilities Act and the Rehabilitation Act. The Supreme Court reversed in part and affirmed in part, holding (1) the FSSA's denial notices were insufficiently explanatory in violation of due process; (2) the FSSA may deny an application for Food Stamp benefit when the applicant fails to cooperate in the eligibility determination process; and (3) Perdue was entitled to reasonable accommodations in applying for benefits, but that did not necessarily require providing a caseworker or case management services.

This case arose when plaintiffs filed a class action complaint under 42 U.S.C. 1983, alleging that the District was violating the Medicaid Act, 42 U.S.C. 1396 et seq. Since 1993, a consent decree has governed how the District provides "early and periodic screening, diagnostic, and treatment services" under the Act. The District has now asked the district court to vacate that decree on two grounds: that an intervening Supreme Court decision has made clear that plaintiffs lack a private right of action to enforce the Medicaid Act, and that in any event, the District has come into compliance with the requirements of the Act. Because the court concluded that the district court's rejection of one of the District's two arguments did not constitute an order "refusing to dissolve [an] injunction[]" within the meaning 28 U.S.C. 1292(a)(1), the court dismissed the appeal for lack of jurisdiction.

Main & Associates, Inc., d/b/a Southern Springs Healthcare Facility, filed an action in the Bullock Circuit Court, on behalf of itself and a putative class of Alabama nursing homes, against Blue Cross and Blue Shield of Alabama (BCBS), asserting claims of breach of contract, intentional interference with business relations, negligence and/or wantonness, and unjust enrichment and seeking injunctive relief. BCBS removed the case to the the federal court, arguing among other things, that Southern Springs' claims arose under the Medicare Act and that the Medicare Act, as amended by the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (the MMA) completely preempted Southern Springs' state-law claims. Southern Springs moved the federal court to remand the case to the circuit court, arguing that the federal court did not have jurisdiction over its claims. The federal court granted the motion and remanded the case to the Bullock Circuit Court. After remand, BCBS moved the circuit court for a judgment on the pleadings, arguing that Southern Springs had not exhausted its administrative remedies and that the circuit court did not have subject-matter jurisdiction over the case. The circuit court denied BCBS's motion, and BCBS petitioned the Supreme Court for a writ of mandamus to direct the circuit court to dismiss Southern Springs' claims. Upon review, the Court concluded that Southern Springs' claims were inextricably intertwined with claims for coverage and benefits under the Medicare Act and that they were subject to the Act's mandatory administrative procedures and limited judicial review. Southern Springs did not exhaust its administrative remedies, and the circuit court did not have jurisdiction over its claims. Therefore, the Court granted BCBS's petition and issue a writ of mandamus directing the circuit court to dismiss the claims against BCBS.