Justia Class Action Opinion SummariesArticles Posted in Public Benefits
Bond v. Martineau
Plaintiffs Kenneth Bond and Deborah Thibault, on behalf of themselves and a class of others similarly situated, appealed a superior court order granting summary judgment to the defendants, the City of Manchester and Paul Martineau in his official capacity as Commissioner of the Manchester Welfare Department (collectively, the City). In January 2010, the plaintiffs applied for general assistance from the City pursuant to RSA chapter 165. See RSA 165:1, I (2002). On February 24, 2010, the City approved $140.00 per week in rental assistance. On March 18, 2010, the City suspended this assistance for seven days because of the plaintiffs' failure to provide certain documentation, including that which related to $30 the plaintiffs used to buy gas for a vehicle. The City lifted this suspension on March 25, 2010, noting that the plaintiffs were "unable to show compliance with the $30 purchase of vehicle gas that [they] stated [they] had previously purchased through an alternate financial resource." On April 9, 2010, the City revoked an April 8 voucher and denied the plaintiffs all assistance for six months because they had misrepresented information related to their vehicle. The plaintiffs petitioned the superior court to enjoin the City from suspending their assistance. Because the Supreme Court held that RSA 165:1-b and the Guidelines pertaining to rental assistance actually conflict, the Court reversed the trial court's grant of summary judgment in favor of the City and remanded the case for further proceedings.View "Bond v. Martineau" on Justia Law
John B. v.Emkes
Tennessee participates in Medicaid through “TennCare,” Tenn. Code 71-5-102. The Medicaid Act requires that TennCare administer an Early and Periodic Screening, Diagnosis, and Treatment program for all enrollees under age 21, 42 U.S.C. 1396a(a)(43), 1396d(r) and must provide outreach to educate its enrollees about these services. In 1998 plaintiffs filed a putative class action under 42 U.S.C. 1983, alleging that TennCare had failed to fulfill these obligations. The district court entered a consent decree that explained in detail the requirements that TennCare had to meet to “achieve and maintain compliance” with the Medicaid Act, based on the assumption that the Act created rights enforceable under section 1983. Eight years later, the Sixth Circuit held that one part of the Medicaid Act was unenforceable under section 1983. Following a remand, the district court vacated paragraphs of the decree that were based on parts of the Act that are not privately enforceable. After a thorough review of TennCare’s efforts, the court then vacated the entire decree, finding that TennCare had fulfilled the terms of the decree’s sunset clause by reaching a screening percentage greater than 80% and by achieving current, substantial compliance with the rest of the decree. The Sixth Circuit affirmed. View "John B. v.Emkes" on Justia Law
Pashby v. Delia
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
NB, et al. v. DC, et al.
Five Medicaid recipients filed a class action against the District, alleging that the District systematically denied Medicaid coverage of prescription medications without providing the written notice required by federal and D.C. law. The district court dismissed the case on the pleadings, concluding that plaintiffs lacked standing to pursue their claims for injunctive and declaratory relief. At least with regard to one plaintiff, John Doe, the allegations sufficiently established injury, causation, and redressability and the court concluded that Doe had standing to pursue his claims for injunctive and declaratory relief. Therefore, the court had no need to decide whether the other plaintiffs had standing and reversed the judgment, remanding for further proceedings. View "NB, et al. v. DC, et al." on Justia Law
Perdue v. Gargano
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. View "Perdue v. Gargano" on Justia Law
Salazar, et al. v. DC, et al.
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. View "Salazar, et al. v. DC, et al." on Justia Law
Pimentel v. Dreyfus, et al.
Plaintiff represented a class of legal immigrants in the state of Washington adversely affected by its recent termination of a state-funded food assistance program for legal immigrants, which exclusively benefitted Washington resident aliens who became ineligible for federal food stamps following the enactment of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, 8 U.S.C. 1601 et seq. Plaintiff contended that the state, by eliminating food assistance to class members while continuing to administer federal food assistance to U.S. citizens and certain qualified aliens, violated the Fourteenth Amendment's Equal Protection Clause and, by failing to provide class members adequate pre-deprivation notice and opportunity to be heard, also violated the Fourteenth Amendment's Due Process Clause. Because plaintiff failed even to allege that the State treated her less favorably than a similarly situated citizen of the State, her claim of alienage discrimination failed on the merits. The court agreed with the State that plaintiff lacked the concrete and particularized interest required for standing to claim a procedural due process violation. Consequently, plaintiff either lacked standing or would not succeed on the merits of her claims. Therefore, the court reversed the district court's order granting the motion for a preliminary injunction, vacated the injunction, and remanded for further proceedings. View "Pimentel v. Dreyfus, et al." on Justia Law
Main & Associates, Inc. v. Blue Cross & Blue Shield of Alabama
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. View "Main & Associates, Inc. v. Blue Cross & Blue Shield of Alabama" on Justia Law
Hawkins v. Dep’t of Health & Human Servs. for the State of NH
In 2003, the New Hampshire Department of Health and Human Services and a certified class of Medicaid-eligible children reached a settlement agreement and proposed a consent decree that outlined the Department's obligations to provide dental services to Medicaid-enrolled children in accordance with federal law. The district court approved the Decree in 2004. Between 2007 and 2010, the district court denied four motions alleging that the Department was not in compliance. The First Circuit affirmed, upholding the district court's requirement that the Class to file a motion for contempt to enforce the Decree; denial of a 2010 motion for contempt; denial of a request for an evidentiary hearing in 2010; and holding the Class to a clear and convincing burden of proof on its 2010 motion to modify or extend the Decree. View "Hawkins v. Dep't of Health & Human Servs. for the State of NH" on Justia Law
Amer. Assoc.of People with Disabilities, et al. v. Harris, et al.
Plaintiffs, visually or manually impaired Florida citizens who were registered to vote in Duval County, Florida and were represented by the American Association of People with Disabilities, filed a putative class action against defendants, alleging that defendants violated federal statutory and state constitutional provisions by failing to provide handicapped-accessible voting machines to visually or manually impaired Florida voters after the 2000 general election. The court vacated its prior opinion and in its revised opinion, held that the district court erroneously granted plaintiffs' requested declaratory judgment and injunction against purported violations of the American with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101-12213, and the regulations promulgated thereunder. The opinion, however, based that outcome exclusively on the ground that voting machines were not "facilities" under 28 C.F.R. 35.151(b).