Medicaid Recipient’s Daughter Cannot Sue in Federal Court over State Court’s Caretaker Child Exception Decision

A federal district court does not have jurisdiction to hear a lawsuit brought by the daughter of a Medicaid recipient challenging the Medicaid agency’s decision to deny her a caretaker child exception because the Medicaid agency and state court have already decided the issue. Thomas v. State of Idaho Department of Health and Welfare (U.S. Dist. Ct., D. Idaho, No. 1:21-cv-00284-CWD, Jan. 11, 2022).

Mary Kitchen received at-home long-term care Medicaid benefits from 2007 to 2015. Her daughter, Mary Thomas, moved into her home in 2011 and provided care for her until her death in 2019. In 2017, Ms. Kitchen transferred her house to Ms. Thomas.

After Ms. Thomas passed away, the state Medicaid agency filed a lien against the house. Ms. Thomas asked to apply the caretaker child exception to the transfer of the house. The Medicaid agency denied the request because Ms. Kitchen was receiving Medicaid benefits before Ms. Thomas moved into the house. After the Medicaid agency and a state court denied her appeal, Ms. Thomas sued the Medicaid agency in federal court, seeking declaratory and injunctive relief. The Medicaid agency filed a motion to dismiss, arguing that the federal court does not have jurisdiction.

The U.S. District Court, District of Idaho, grants the Medicaid agency’s motion to dismiss, holding that the court does not have jurisdiction. The court “finds that the Rooker-Feldman doctrine prohibits [Ms.] Thomas from utilizing the claims asserted in this case as a vehicle to appeal the earlier adverse rulings she received from the [Medicaid agency] and the state court.”

For the full text of this decision, click here.

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