Justia Government & Administrative Law Opinion Summaries

Appellant in this case was a nine-year-old boy with severe autism, epilepsy, and chronic seizures. The Commissioner of the Minnesota Department of Human Services (DHS) found that Appellant was not dependent in "mobility" and therefore reduced his authorized personal care assistant (PCA) services covered through the Minnesota Medical Assistance program. The district court reversed the Commissioner's decision, concluding that Minn. Stat. 256B.0659 did not require Appellant to be physically incapable of mobility to be eligible for covered services. The court of appeals reversed because Appellant was physically able to begin and complete moving from place to place without assistance. At issue was whether a person who is physically able to move without assistance but lacks the ability to direct his movement to a specific location has a dependency in mobility under the statute. The Supreme Court affirmed, holding that the Commissioner's interpretation of the statute was supported by the plain and ordinary meaning of "mobility." View "A.A.A. v. Dep't of Human Servs." on Justia Law

Elgin sought review of a final decision by DHHS upholding a ruling of an ALJ affirming a determination by the CMS that Elgin had violated certain safety requirements by serving "undercooked" eggs to its elderly residents. The court concluded it would not defer to DHHS's interpretation of the State Operations Manual (SOM); there was not substantial evidence to find that Elgin violated the SOM; and DHHS could not issue ambiguous interpretative documents and then interpret those in enforcement actions. Accordingly, the court granted the petition for review and set aside the finding of deficiency and resultant penalties. View "Elgin Nursing Center v. U.S. Dept. of Health and Human Services" on Justia Law

Child was born with birth-related neurological injuries. Child's parents (Petitioners) filed a claim for compensation under the Florida Birth-Related Neurological Injury Compensation Plan. The Florida Birth-Related Neurological Injury Compensation Association agreed to pay parental compensation of $100,000 to both parents jointly under Fla. Stat. 766.31(1)(b)(1), which provides for an award not exceeding $100,000 to the parents or legal guardians of an infant found to have sustained a birth-related neurological injury. Petitioners reserved the right to have a hearing before an ALJ to raise the issue of the interpretation and constitutionality of section 766.31(1)(b)(1). The ALJ denied Petitioners' claim for an additional $100,000 as part of the parental award, finding that the Legislature clearly intended that the maximum award of $100,000 was for both parents, not for each parent. The district court upheld the ALJ's judgment and denied each of Petitioners' constitutional claims. The Supreme Court approved the district court's decision, holding that the parental award provision (1) unambiguously provides for only a single award of $100,000; (2) does not violate equal protection; and (3) neither is void for vagueness nor unconstitutionally limits the right of access to courts. View "Samples v. Fla. Birth Related Neurological Injury Comp. Ass'n" on Justia Law

In 2000, Appellant was indeterminately committed as a sexual dangerous person as a result of a series of sex offenses involving teenage girls. Appellant later petitioned for provisional discharge from civil commitment. After weighing the evidence presented by Appellant and the Commissioner of Human Services at a first-phase hearing, the Supreme Court Judicial Appeal Panel dismissed Appellant's petition under Minn. R. Civ. P. 41.02(b). The court of appeals affirmed. The Supreme Court reversed, holding that the Appeal Panel committed reversible error in applying Rule 41.02(b) by failing to view the evidence produced at the first-phase hearing in a light most favorable to Appellant and by weighing the evidence produced during the first phase of the hearing. Remanded. View "Coker v. Jesson" on Justia Law

Respondent was an inmate in the custody of the State Department of Corrections and Correctional Services (DOCCS). In 2010, Respondent undertook a month-long hunger strike, contending that he had ceased eating in order to secure transfer to another DOCCS facility and to bring attention to certain claims of mistreatment. After Respondent had lost 11.6 percent of his body weight, DOCCS commenced this proceeding requesting a court order permitting medical personnel to insert a nasogastric tube and take other reasonable steps necessary to provide hydration and nutrition to Respondent. Supreme Court granted DOCCS' motion. Respondent subsequently resumed eating solid food but nevertheless appealed. The Appellate Division concluded the case was moot except for the issue of whether the State violated Respondent's rights by securing the force-feeding order. On that issue, the Appellate Division ruled in favor of DOCCS, concluding that the force-feeding order did not violate Respondent's right to refuse medical treatment. The Court of Appeals affirmed, holding that Respondent's rights were not violated by the judicial order permitting the State to feed him by nasogastric tube after his health devolved to the point that his condition became life-threatening. View "Bezio v. Dorsey" on Justia Law

Appellant was employed by Employer when he suffered a compensable work-related brain injury. Appellant, who was permanently and totally disabled, filed a workers' compensation claim seeking benefits and also requested benefits for the nursing care services his mother was providing. The workers' compensation commission (Commission) found Appellant's injury was compensable but denied the requested nursing service benefits. Appellant subsequently made a second request for additional benefits in the form of nursing services at Timber Ridge Ranch, an assisted living facility. The Commission denied Appellant benefits, finding that the services at Timber Ridge were not nursing services as defined by the law. The court of appeals affirmed. The Supreme Court reversed, holding that the Commission's findings and conclusions were not supported by substantial evidence and that the services provided at Timber Ridge qualified as nursing services under the applicable statutes. Remanded. View "Pack v. Little Rock Convention Ctr. & Visitors Bureau" on Justia Law

Southwest appealed the district court's dismissal of its claim regarding the Medicare Part D statute, 42 U.S.C. 1395w-101 et seq., for lack of subject matter jurisdiction. Citing Shalala v. Illinois Council on Long Term Care, Southwest argued that its claim provided a narrow exception to 42 U.S.C. 405(h)'s requirement that required a plaintiff to exhaust administrative remedies before filing a claim in federal court. The court concluded that caselaw interpreting the application of section 405(h) to Medicare claims emphasized that the Illinois Council exception was extremely narrow and appropriately applied only in cases where judicial review would be entirely unavailable through the prescribed administrative procedures. Because Southwest has not carried its heavy burden of showing that the Illinois Council exception applied, the court affirmed the district court's order dismissing the suit. View "Southwest Pharmacy Solutions, Inc. v. Centers for Medicare & Medicaid, et al" on Justia Law

Under the Federal Mine Safety & Health Act of 1977, the Secretary of Labor protects the health and safety of miners, acting through the Federal Mine Safety and Health Administration (MSHA). Regulations under the Act require mine operators to report all mine-related injuries and illnesses suffered by employees. In 2010, MSHA acted on a new and broader interpretation and informed 39 mine operators that they would be required to permit MSHA inspectors to review employee medical and personnel records during inspections. Two operators refused to provide the records. MSHA issued citations and imposed penalties. An ALJ and the Review Commission found that the demands and enforcement were lawful under 30 U.S.C. 813(h) and 30 C.F.R. 50.41. Mine employees intervened to raise personal privacy challenges. The Seventh Circuit denied a petition for review, rejecting arguments that MSHA does not have authority for the requirement; that 30 C.F.R. 50.41 is not a reasonable interpretation of the Act and was not properly promulgated; that the requirement infringes operators’ Fourth Amendment right not to be searched without a warrant; that the demands violate the miners’ Fourth Amendment privacy rights in their medical records; and that penalties imposed for noncompliance violate the operators’ Fifth Amendment due process rights. View "Bickett v. Fed. Mine Safety & Review Comm'n" on Justia Law

"At its most basic level, this case presents a policy dispute: whose policy choice concerning health insurance premiums for State employees controls—the General Assembly's or the Budget and Control Board's?" The issue before the Supreme Court centered on "maintaining and enforcing the constitutional and statutory framework through which such issues must be resolved. " Upon review of the arguments of the parties and the applicable case law, the Supreme Court found that the General Assembly had and exercised the power to determine the contribution rates of enrollees for the State's health insurance plan in 2013. The Court held that the Budget and Control Board violated the separation of powers provision by substituting its own policy for that of the General Assembly, entered judgment for the petitioners, and directed the Board to use the appropriated funds for premium increases and return the premium increases previously collected from enrollees. View "Hampton v. Haley" on Justia Law

Under the Medicaid program, the federal government offsets some state expenses for medical services to low-income persons; a state’s plan must cover medical assistance for specific populations, but a state may expand its Medicaid program by obtaining a waiver for an “experimental, pilot, or demonstration project.” In 1993, Tennessee obtained a waiver for TennCare, to cover uninsured and uninsurable individuals. Following approval, hospitals received reimbursement under the umbrella of TennCare. Because hospitals serving large numbers of low-income patients generally incur higher costs than Medicaid flat payment rates reflect, hospitals that treated a disproportionate share of low-income patients could apply for the “DSH” adjustment. A fiscal intermediary processed requests for reimbursement, including DSH adjustment payments. Due to discrepancies between the practices of fiscal intermediaries in different states, the Secretary issued a 2000 rule, providing that eligibility waiver patients were to be included as individuals “eligible for medical assistance” under Medicaid for purposes of DSH adjustment calculations. The 2005 Deficit Reduction Act ratified the rule. Adventist, a not-for-profit hospital network, provided more than 1,200 patient care days to TennCare expansion waiver patients 1995-2000. The fiscal intermediary did not include those days in calculating the adjustment. The Secretary’s Provider Reimbursement Review Board upheld the exclusion. The district court dismissed, concluding that section 1315 provided the Secretary discretion to exclude expansion waiver patient days from the DSH calculation. The Sixth Circuit affirmed. View "Adventist Health Sys./Sunbelt, Inc. v. Sebelius" on Justia Law