Unan v. Lyon

While implementing changes required by the Patient Protection and Affordable Care Act of 2010, Michigan experienced a systemic computer problem that erroneously assigned thousands of non-citizens, who may have been eligible for comprehensive Medicaid coverage, to Emergency Services Only (ESO) Medicaid. Plaintiffs, two eligible noncitizen residents of Michigan who were erroneously assigned ESO coverage, filed a class action complaint against the Director of the Michigan Department of Health and Human Services, alleging violations of the Medicaid statute and the Due Process Clause. The district court found that actions taken by the state since the complaint was filed had resolved all systemic errors, so that plaintiffs’ claims were moot. The Sixth Circuit reversed the summary judgment, noting that not one of the individuals identified as a named plaintiff or potential named plaintiff was granted relief on the basis of a systemic fix and that that it is not “absolutely clear the allegedly wrongful behavior could not reasonably be expected to recur.” Material questions of fact remain regarding claims that the state failed to provide comprehensive Medicaid coverage and a reasonable opportunity to verify immigration status, precluding summary judgment. View "Unan v. Lyon" on Justia Law