Nursing Home's Suit Claiming State Wrongly Denied and Delayed Medicaid Applications Is Barred by 11th Amendment

The 4th Circuit U.S. Court of Appeals holds that a nursing home's lawsuit against the state on behalf of residents it claims were wrongly denied Medicaid benefits is barred by the Eleventh Amendment and is moot. Wicomico Nursing Home v. Padilla (U.S. Ct. App., 4thCircuit, No. 17-1972, Dec. 6, 2018).

Wicomico Nursing Home filed a lawsuit on behalf of eleven of its residents against the secretary of the Maryland Department of Human Services and the secretary of the Maryland Department of Health, claiming that the state violated federal law by not obtaining the Medicaid residents' information electronically and failing to issue timely Medicaid eligibility determinations.

The state filed a motion to dismiss, arguing that it is entitled to sovereign immunity under the Eleventh Amendment because the nursing home was seeking retroactive relief. All of the residents whom the nursing home alleged were harmed are currently receiving Medicaid benefits or are deceased. The U.S. district court granted the motion to dismiss, and the nursing home appealed.

The U.S. District Court of Appeals, Fourth Circuit, affirms, holding that the nursing home's claims are barred by the Eleventh Amendment. The court holds that because the nursing home was seeking "an award of Medicaid benefits or payments for past medical services dating back to the residents’ dates of eligibility," it was seeking retroactive relief. In addition, the court holds that the claim for prospective injunctive and declaratory relief is moot because the residents who were harmed are now receiving benefits.

For the full text of this decision, go to: http://www.ca4.uscourts.gov/opinions/171972.P.pdf

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