Justia Public Benefits Opinion Summaries

The Court granted certiorari in these cases to decide whether Medicaid providers and recipients could maintain a cause of action under the Supremacy Clause to enforce a federal Medicaid law. Since the Court granted certiorari, however, the relevant circumstances have changed. The federal agency in charge of administering Medicaid, CMS, approved the state statutes as consistent with the federal law. In light of the changed circumstances, the Court believed that the question before it was whether, once the agency approved the state statutes, groups of Medicaid providers and beneficiaries could still maintain a Supremacy Clause action asserting that the state statutes were inconsistent with the federal Medicaid law. Given the present posture of the cases, the Court did not address whether the Ninth Circuit properly recognized a Supremacy Clause action to enforce the federal law before the agency took final action. To decide whether these cases could proceed under the Supremacy Clause now that the agency has acted, it would be necessary on remand to consider at least the matters addressed by the Court. Accordingly, the Court vacated the judgment and remanded for further proceedings.View "Douglas v. Independent Living Center of Southern Cal., Inc." on Justia Law

In enacting comprehensive welfare reform in 1996, Congress rendered various groups of aliens ineligible for federal benefits and also restricted states' ability to use their own funds to provide benefits to certain aliens. As a condition of receiving federal funds, Congress required states to limit eligibility for federal benefits, such as Medicaid, to citizens and certain aliens. Plaintiffs filed suit claiming that Basic Health Hawai'i violated the Equal Protection Clause of the Fourteenth Amendment because it provided less health coverage to nonimmigrant aliens residing in Hawai'i (COFA Residents) than the health coverage that Hawai'i provided to citizens and qualified aliens who are eligible for federal reimbursements through Medicaid. The court concluded that Congress has plenary power to regulate immigration and the conditions on which aliens remain in the United States, and Congress has authorized states to do exactly what Hawai'i had done here - determine the eligibility for, and terms of, state benefits for aliens in a narrow third category, with regard to whom Congress expressly gave states limited discretion. Hawai'i has no constitutional obligation to fill the gap left by Congress's withdrawal of federal funding for COFA Residents. Accordingly, the court vacated the district court's grant of a preliminary injunction preventing Hawai'i from reducing state-paid health benefits for COFA Residents because Hawai'i is not obligated to backfill the loss of federal funds with state funds and its decision not to do so was subject to rational-basis review. View "Korab v. Fink" on Justia Law

Plaintiffs placed their son in a specialized private school designed to educate children with learning disabilities and filed suit against the District for tuition reimbursement under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. An Impartial Hearing Officer (IHO) awarded tuition reimbursement but the State Review Officer (SRO) reversed. The court held that the SRO's decision was insufficiently reasoned to merit deference and deferred to the IHO's decision, which was more thorough and carefully considered. The court affirmed the dismissal of plaintiff's claim under Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794, where the parents had not presented sufficient evidence of bad faith or gross misjudgment. View "C.L. v. Scarsdale Union Free Sch. Dist." on Justia Law

Plaintiffs filed suit against the Secretary of Health and Human Services (HHS) and the Commissioner of the Social Security Administration (SSA) raising constitutional challenges to the Patient Protection and Affordable Care Act (ACA), Pub. L. No 111-148, 124 Stat. 119; raising statutory challenges to actions of HHS and the Commissioner relating to the implementation of the ACA and prior Medical legislation; and attacking the failure of defendants to render an "accounting" that would alter the American people to the insolvency towards which Medicare and Social Security programs were heading. On appeal, plaintiffs challenged the district court's dismissal of their claims. The court rejected plaintiffs' claims that 26 U.S.C. 5000A, which was sustained as a valid exercise of the taxing power, violated the Fifth Amendment's prohibition of the taking of private property without just compensation and violated the origination clause. The court concluded that plaintiffs' substantive attack on the Social Security Program Operations Manual System (POMS) provisions was clearly foreclosed by its decision in Hall v. Sebelius, holding that the statutory text establishing Medicare Part A precludes any option not to be entitled to benefits. The court rejected plaintiffs' second statutory claim attacking an interim final rule. Finally, the court concluded that plaintiffs failed to provide a legal argument for their claims against the Commissioner and Secretary, and therefore, the court lacked jurisdiction over plaintiffs' claim to an "accounting." Accordingly, the court affirmed the judgment of the district court. View "Assoc. Amer. Physicians, et al. v. Sebelius, et al." on Justia Law

Before 1992, Chicago police officers received pension credit for time worked for the Cook County Sheriff’s Department. In 1992, the Retirement Board began denying pension credit to retiring officers for prior service with the Sheriff’s Department. In 2008, the Illinois Appellate Court ruled that this practice was improper under the Illinois Pension Code. Officers who had been denied pension credit sought reconsideration. The Board concluded that it lacked jurisdiction to reconsider the final rulings after the statutory 35‐day limit. The officers did not seek review in state court, but filed a federal suit on behalf of themselves and other similarly situated officers, alleging violations of procedural due process and equal protection rights under the U.S. and state constitutions. The district court dismissed. The Seventh Circuit affirmed, reasoning that the officers’ complaint is, essentially, that Illinois law provides no procedure for making the appellate decision retroactive Their sole remedy lies with the political branches of Illinois government. View "Rasario v. Ret. Bd. of the Policemens' Annuity & Benefit Fund" on Justia Law

Plaintiffs, on behalf of their daughter, filed suit challenging the district's implementation of a new individualized education program (IEP) for their daughter under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. Determining that the daughter's case was not moot, the court concluded that the court need not decide whether the various notice requirements were satisfied because whatever notice deficiencies there could have been in this case, they did not warrant relief; there was no error in requiring the parents to present a complaint and demand a due process hearing because they disagreed with the IEP team's decision; the district court correctly stated the Loren F. ex. rel. Fisher v. Atlanta Independent School System standard, fully reviewed the administrative record, and independently analyzed each of the parents' claims; the district court did not abuse its discretion when it issued the parents' proposed order and then decided the case on summary judgment; and the court held that 42 U.S.C. 1983 actions for denial of rights conferred by the IDEA were barred because the IDEA's comprehensive enforcement scheme provided the sole remedy for statutory violations and, therefore, the district court did not err in dismissing the parents' section 1983 claims. Accordingly, the court affirmed the judgment of the district court. View "K.A. v. Fulton County Sch. Dist." on Justia Law

Plaintiff first applied for social security disability insurance (SSI) benefits ten years ago. When the benefits were denied, plaintiff requested a hearing but the SSA ruled that her request was untimely and denied a subsequent application on the ground of res judicata. The SSA never explained why it rejected plaintiff's facially valid excuse for the delay in her hearing request. The district court then dismissed her action for lack of subject matter jurisdiction. The court reversed and remanded, concluding that the ALJ failed to consider whether plaintiff's facially valid reasons constituted good cause excusing the delay, and deprived plaintiff of her due process right to a meaningful opportunity to be heard and to seek reconsideration of an adverse benefits determination. View "Dexter v. Astrue" on Justia Law

Plaintiff and his wife appealed the denial of his application for Medicaid benefits, arguing that the Department wrongfully denied the application because it had improperly counted against the wife's eligibility an annuity owned by the wife. The district court ruled in favor of plaintiffs and the Department appealed. The court concluded that, because the wife had no right, authority, or power to liquidate the annuity, the annuity benefits were not a resource, but rather was income indicated by the federal statute defining "unearned income." Therefore, the Department applied a more restrictive methodology under state law by classifying the annuity benefits as a resource that counted against plaintiff's eligibility for Medicaid benefits. The court rejected the Department's counter-arguments and the remaining arguments, and affirmed the judgment of the district court. View "Geston, et al. v. Anderson" on Justia Law

The Secretary appealed the district court's order certifying a nationwide class of Medicare beneficiaries and granting summary judgment in the beneficiaries' favor. The beneficiaries raised two claims: (1) the Secretary's practice of demand "up front" reimbursement for secondary payments from beneficiaries who have appealed a reimbursement determination or sought waiver of the reimbursement obligation was inconsistent with the secondary payer provisions of the Medicare statutory scheme; and (2) the Secretary's practice violated their due process rights. The court concluded that Patricia Haro had Article III standing on behalf of the class; John Balentine, as counsel for Haro, had Article III standing on his individual claim; and the beneficiaries' claims for injunctive relief were not moot and Article III's justiciability requirements were satisfied. The court concluded, however, that the beneficiaries' claim was not adequately presented to the agency at the administrative level and therefore the district court lacked subject matter jurisdiction under 42 U.S.C. 405(g). On the merits of Balentine's claim, the court concluded that the Secretary's interpretation of the secondary payer provisions was reasonable. Therefore, the court vacated the district court's injunctions, reversed the district court's summary judgment order, and remanded for consideration of the beneficiaries' due process claim. View "Haro v. Sebelius" on Justia Law

A 2010 fire at an apartment in Erie, Pennsylvania took the lives of a tenant and her guest. The third-floor bedroom purportedly lacked a smoke detector and an alternate means of egress, both of which are required under the Section 8 housing choice voucher program (42 U.S.C. 1437f) in which Richardson participated. The district court rejected a defense of qualified immunity in a suit under 42 U.S.C. 1983 by the estates of the deceased. The Third Circuit reversed. State officials’ approval and subsidization of the apartment for the Section 8 program, even though the apartment allegedly failed to comply with Section 8’s standards, did not constitute a state-created danger toward the apartment’s tenant and her guest in violation of their constitutional substantive due process rights. View "Henry v. City of Erie" on Justia Law