Justia Class Action Opinion Summaries

Plaintiff, on behalf of a class of similarly situated plaintiffs who received Medicaid assistance and were subject to a Medicaid lien pursuant to 53-2-612, MCA, sued defendant alleging that defendant had collected a greater amount than it was entitled from plaintiffs' recoveries from other sources. The parties raised several issues on appeal. The court held that Ark. Dept. of Health & Human Servs. v. Ahlborn applied retroactively to all class members' claims and that defendant must raise affirmative defenses with respect to individual class members to avoid Ahlborn's effect. The court held that the applicable statute of limitations to be 27-2-231, MCA, which provided for a five-year limitations period. The court declined to disturb the district court's order requiring defendant to compile data on individual class members' claims. The court reversed the district court's determination as to interest assessed against defendant, and concluded that no interest could be assessed until two years after any judgment had been entered, under 2-9-317, MCA. The court concluded that the term "third party" in the Medicaid reimbursement statutes included all other sources of medical assistance available to Medicaid recipients, including private health or automobile insurance obtained by the Medicaid recipient. The court reversed the district court's grant of summary judgment to the class on its proffered distinction between "first party" and "third party" sources. The court affirmed the district court's conclusion that plaintiffs' "made whole" claim was immaterial in light of Ahlborn.

Plaintiffs, a class of indigent children who suffered from severe emotional and mental disabilities, sued Idaho state officials more than three decades ago, alleging that the officials were providing them with inadequate care in violation of their constitutional and statutory rights. The parties reached agreements intended to remedy deficiencies in care and those agreements were embodied in three consent decrees entered and monitored by the district court. Plaintiffs appealed the 2007 order of the district court finding that defendants had substantially complied with the remaining Action Items, which were specified in an Implementation Plan that resulted from the third consent decree, asserting that it was error for the district court to apply the standard for civil contempt in determining whether to vacate the decrees. Plaintiffs further contended that the district court committed errors in fact and law in issuing protective orders barring them from taking supplemental depositions of appellee and two non-parties. The court held that the district court's application of the contempt standard with the imposition of the burden of proof on plaintiffs was error where the district court accepted the Action Items as the entire measure of compliance with the consent decree. Accordingly, the court reversed the order of the district court. The court also held that the district court committed no errors in upholding the assertion of the deliberative process privilege to one non-party and appellee, as well as the legislative privilege to the second non-party. Accordingly, the court did not abuse its discretion in issuing the protective orders.

The State appealed a three-judge district court order directing California to remedy two ongoing violations of the Cruel and Unusual Punishments Clause, a guarantee binding on the States by the Due Process Clause of the Fourteenth Amendment, by reducing the prison system population where the violations were the subject of two class actions involving a class of prisoners with serious mental disorders and a class of prisoners with serious medical conditions. At issue was whether the remedial order issued by the three-judge court was consistent with requirements and procedures set forth in a congressional statute, the Prison Litigation Reform Act of 1995 ("PLRA"), 18 U.S.C. 3626. The Court held that the court-mandated population limit was necessary to remedy the violation of prisoners' constitutional rights and was authorized by the PLRA.

Plaintiffs sued defendants, the Housing Authority of the City of New Haven, alleging that defendants discriminated against them in administering New Haven's Housing Choice Voucher ("Section 8") program in violation of plaintiffs' rights under the Fair Housing Act ("FHA"), 42 U.S.C. 3604(d); the Fair Housing Amendments Act of 1988 ("FHAA"), 42 U.S.C. 3604(f), and section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794, as well as regulations promulgated thereunder, 24 C.F.R. 8, 28, 100.204. At issue was whether the district court erred in concluding that 24 C.F.R. 8, 28, and 100.204 could not be privately enforced through 42 U.S.C. 1983; in the analysis of plaintiffs' intentional discrimination claim under the FHAA; in factual findings regarding the provision of Section 8 services to the class; in rulings on certain discovery issues; and in decertification. The court adopted the district court's findings and conclusions and held that the district court carefully considered and thoroughly discussed these issues. The court also considered plaintiffs' remaining arguments and held that they were without merit.