A Kentucky appeals court dismisses a case as moot due to lack of actual injury because the appellant was protected from a penalty by a temporary federal law during the coronavirus pandemic. Singleton v. Cabinet for Health and Family Services (No. 2024-CA-0879-MR, February 21, 2025).
Yasuko Singleton has been receiving Medicaid benefits since 2021. She is living in a long-term care facility paid for by Medicaid. In May 2022, she sold her house for $70,000. Ms. Singleton’s late husband was a joint owner of the property. Her son, Edwin Singleton, inherited a quarter interest in the property. Ms. Singleton’s net share of the sale of the house was $52,340, which was deposited into her bank account.
A month after receiving the proceeds from the sale of the house, Ms. Singleton used the proceeds and the trade-in value for a 2020 Land Rover that was titled in her name to help Mr. Singleton purchase a 2022 Porsche Cayenne. The total cost of the Porsche exceeded $100,000 and it was titled “Singleton, Edwin or Singleton, Yasuko.” Mr. Singleton purchased and titled the Porsche in Alabama, where he lives. There is no evidence that Ms. Singleton has received any benefit from her part ownership in the vehicle.
Through her authorized representative, Ms. Singleton informed the Cabinet for Health and Family Services of the transfer of assets. The Cabinet sent Ms. Singleton a letter informing her that a disqualification penalty would be imposed between June 2022 and September 2022 for a prohibited transfer of resources. Ms. Singleton requested a hearing with the Division of Administrative Hearings to contest the penalty. The hearing occurred in September 2022.
Prior to the hearing, the Cabinet filed a motion to dismiss the proceeding as moot. Due to the Families First Coronavirus Response Act (FFCRA), the Cabinet was unable to discontinue Ms. Singleton’s benefits. Even if the administrative hearing were to be resolved in the Cabinet’s favor, it would be unable to recoup any of the benefits Ms. Singleton had received.
The Cabinet’s final order was issued in November 2023, stating that a prohibited transfer had occurred, and the assessed penalty was warranted. That same month, Ms. Singleton filed a petition for judicial review in circuit court. The circuit court issued its order in July 2024, affirming the Cabinet’s decision. This is the order Ms. Singleton is appealing.
The court finds that Ms. Singleton gave up control of her proceeds from the sale of the house and the trade-in value of the Land Rover when she put those assets toward the purchase of the Porsche. Since the Porsche is titled to either her or her son, he could sell it without her consent and keep the proceeds from the sale. It is hard to argue that this vehicle can be used for Ms. Singleton’s benefit since she and her son live in different states, and she no longer has a driver’s license. This is the circumstance that led the Cabinet to impose a penalty on Ms. Singleton.
However, the Cabinet argues that this case is moot since Ms. Singleton’s penalty period took place during a period when a temporary federal law was in place that prohibited Medicaid benefits from being revoked unless under circumstances that don’t apply here. Therefore, Ms. Singleton did not suffer any injury that can be redressed by the circuit court or the court of appeals.
Because an opinion on this case will not affect Ms. Singleton’s rights or redress any actual injury, the court deems this case moot and dismisses the appeal.
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