Justia Civil Procedure Opinion Summaries

Genesis Healthcare was a healthcare provider participating in the federal “340B Program,” which was designed to provide drugs to qualified persons at discounted prices. Under the Program, the Secretary of the Department of Health and Human Services (“HHS”) enters into agreements with drug manufacturers to sell drugs at discounted prices to entities such as Genesis Healthcare, which could, in turn, sell the drugs to their patients at discounted prices. After Genesis Healthcare purchased the covered drugs from the manufacturers, it dispensed them to patients through its wholly owned pharmacies or contract pharmacies. After the Health Resources and Services Administration (“HRSA”) conducted an audit of Genesis Healthcare in June 2017 for Program compliance, HRSA removed Genesis Healthcare from the 340B Program. The audit report found, among other things, that Genesis Healthcare dispensed 340B drugs to individuals who were ineligible because they were not “patients” of Genesis Healthcare. HRSA rejected Genesis Healthcare’s challenges; Genesis Healthcare, in turn, filed suit seeking a declaration it did not violate the requirements of the Program, and injunctive relief requiring HRSA to reinstate it into the Program and to retract any notifications that HRSA had provided to manufacturers stating that Genesis Healthcare was ineligible under the Program. In response to the lawsuit, HRSA ultimately: (1) notified Genesis Healthcare by letter that it “ha[d] voided” all audit findings and that Genesis Healthcare “ha[d] no further obligations or responsibilities in regard to the audit” and (2) filed a motion to dismiss Genesis Healthcare’s action as moot based on the letter. The district court granted HRSA’s motion, finding that the action was moot. The Fourth Circuit reversed the district court's finding the case was moot: Genesis Healthcare continued to be governed by a definition of “patient” that, Genesis maintained, was illegal and harmful to it. Therefore, there remained a live controversy between the parties. View "Genesis HealthCare, Inc. v. Becerra" on Justia Law

In 2016, plaintiff Stephanie Hargrove filed suit against defendants-respondents San Bernardino Convalescent Operations, Inc., dba Legacy Post-Acute Rehabilitation Center (Hargrove’s former employer; SBCO), Indio Nursing & Rehabilitation Center, Inc. (another skilled nursing facility where Hargrove was never employed; INRC), and Legacy Healthcare, Inc. (managerial and support services corp.; Legacy) under the Labor Code Private Attorneys General Act of 2004 (PAGA). Approximately four years later, in 2020, Hargrove died. Her attorneys requested leave to file an amended pleading to substitute movant-appellant Makiya Cornell in place of Hargrove to prosecute the PAGA claims; however, on October 6, 2020, the trial court denied the request, dismissed the action, and stated that Cornell “is free to file her own claim and her own causes of action.” On appeal, Cornell contends that she had standing to appeal the trial court’s order denying her request to substitute herself in place of Hargrove as an order effectively denying a motion to intervene. Alternatively, Cornell argued the Court of Appeal could treat her appeal as a petition for writ of mandate. Assuming the Court concluded Cornell had standing to appeal, she argued the trial court abused its discretion in refusing to permit her to amend Hargrove’s complaint to substitute Cornell as the representative plaintiff such that her PAGA claim related back to the original complaint. The Court of Appeal concluded Cornell did not have standing to appeal the judgment. The Court treated the order denying to motion to amend as an order denying an implicit motion to intervene, and concluded the trial court did not abuse its discretion in denying the motion. View "Hargrove v. Legacy Healthcare, Inc" on Justia Law

Defendant-respondent Inland Empire Health Plan (IEHP) was a health care service plan subject to the Knox-Keene Health Care Service Plan Act of 1975 (Knox-Keene Act). It contracted with certain medical groups and providers to provide medical care at reduced costs to eligible beneficiaries of the California Medical Assistance Program (Medi-Cal or Medicaid) who were enrolled with IEHP. Plaintiffs-appellants Allied Anesthesia Medical Group, Inc., and Upland Anesthesia Medical Group were groups of doctors who provided anesthesia services to IEHP’s enrollees for elective, nonemergency surgeries. Plaintiffs had no provider contract with IEHP; however, they had exclusive agreements with the hospitals. Plaintiffs were paid at the Medi-Cal fee schedule rate. In this case, plaintiffs claimed IEHP should have paid them at the reasonable and customary value rate for their services instead of the Medi-Cal fee schedule rate, and requested a declaratory judgment based solely upon the Knox-Keene Act and the Claims Settlement Practices regulation. IHEP demurred on several grounds, including: (1) the cause of action for breach of implied-in-fact contract fails to sufficiently plead “mutual assent” and “legal consideration”; and (2) the cause of action for breach of contract (third party beneficiary) failed to allege how plaintiffs were the express, intended third party beneficiaries of any contract between IEHP and the California Department of Health Care Services. The trial court agreed with IEHP, sustained its demurrer without leave to amend, and entered judgment. Plaintiffs appealed, maintaining IEHP was obligated to pay them the reasonable and customary value rate for their services to IEHP’s enrollees. To this the Court of Appeal disagreed and affirmed the trial court. View "Allied Anesthesia Medical Group v. Inland Empire Health Plan" on Justia Law

Plaintiff-appellant Amber Machowski was an individual with a disability who used a wheelchair for mobility. Defendant 333 N. Placentia Property, LLC, was the owner of a property in Fullerton, California, on which a business establishment known as City Market Liquor II was located. When Machowski attempted to patronize the store, she encountered architectural barriers that prevented her from making full use and enjoyment of the premises. Machowski sued Defendant, asserting claims under the Americans with Disabilities Act, and the Unruh Civil Rights Act. The complaint sought injunctive relief, statutory damages under the Unruh Act, and reasonable attorney’s fees and costs. After Defendant failed to respond to the complaint, Machowski applied for the entry of default judgment, seeking injunctive relief and statutory damages. Machowski’s application for default judgment did not seek an award of attorney’s fees. Instead, it advised the district court that “plaintiff will separately file a motion for her attorney fees and costs once this application is granted and judgment has been entered.” The district court declined to exercise supplemental jurisdiction over Machowski’s Unruh Act claim, granted default judgment on her ADA claim, ordered injunctive relief, and sua sponte awarded Machowski $1000 in attorney’s fees under Central District of California Local Rule 55-3. Machowski timely appealed the fee award. The Ninth Circuit held that where, as here, a prevailing party advises the district court that it is opting out of the fee schedule and will seek by motion, an award of reasonable attorney's fees, the district court abuses its discretion by disregarding the plaintiff's choice and sua sponte awarding fees under the fee schedule. Accordingly, the fee award was vacated and the matter remanded for further proceedings. View "Machowski v. 333 N. Placentia Property, LLC" on Justia Law

A nonprofit organization called California River Watch claimed that the City of Vacaville, California was violating the Resource Conservation and Recovery Act (“RCRA”). River Watch claimed the City’s water wells were contaminated by a carcinogen called hexavalent chromium. That carcinogen, River Watch says, was in turn transported to the City’s residents through its water-distribution system. River Watch’s argument on appeal was that because the hexavalent chromium originated from the Wickes site, it was “discarded material” under RCRA, and thus the City was liable for its transportation through its water-distribution system. The parties cross-moved for summary judgment. The district court granted the City’s motion and denied River Watch’s motion because, as it explained, River Watch hadn’t demonstrated how the City’s water-processing activities could qualify as discarding “solid waste” under RCRA. Thus, the district court explained, RCRA’s “fundamental requirement that the contaminant be ‘discarded’” was not satisfied. River Watch appealed. The Ninth Circuit was satisfied that hexavalent chromium met RCRA's definition of "solid waste." However, the Court found RCRA’s context makes clear that mere conveyance of hazardous waste cannot constitute “transportation” under the endangerment provision. Under the facts presented, the Court found the City did not move hexavalent chromium in direct connection with its waste disposal process. Under River Watch’s theory of liability, hexavalent chromium seeped through groundwater into the City’s wells and the City incidentally carried the waste through its pipes when it pumps water to its residents. The Court concluded City did not have the necessary connection to the waste disposal process to be held liable for “transportation” under § 6972(a)(1)(B) of the Act. Because the City could not be held liable under RCRA, the district court’s grant of summary judgment for the City was affirmed. View "California River Watch v. City of Vacaville" on Justia Law

A sheriff’s deputy sexually abused J.T.H.’s 15-year-old son. J.T.H., who also worked in law enforcement, threatened to sue for the abuse. Before long, Spring Cook, a child-welfare investigator, showed up at his door after someone had apparently called the child-abuse hotline and accused J.T.H. (and his wife) of neglect. The parents asked for the case to be reassigned to an investigator from another county, but Cook kept it for herself. Cook ultimately issued a preliminary written finding of neglect. Unsatisfied with the outcome, the parents requested a formal administrative review. Cook was the circuit manager, so she reviewed and upheld her own finding. The second step required Cook, the parents, and their attorney to appear before Missouri’s Child Abuse and Neglect Review Board. Following that meeting, the Board concluded that Cook’s findings of “neglect were unsubstantiated.” The parents sued Cook for allegedly retaliating against them for exercising their First Amendment rights. The magistrate judge, acting by consent of the parties, concluded that neither absolute nor qualified immunity applied. The Eighth Circuit reversed: "the availability of absolute immunity depends on 'the nature of the function performed,' not the type of claim brought. ... So even if there is a general right to be free of retaliation, the law is not clearly established enough to cover the 'specific context of the case': retaliatory investigation. Cook is entitled to qualified immunity for both investigative acts." View "J.T.H. v. Cook" on Justia Law

Ila Reid appealed a district court’s summary judgment dismissal of her breach of contract claim against Primerica Life Insurance Company (“Primerica”). Reid brought her claim after Primerica filed an interpleader action to resolve competing claims to her late husband Garvin Reid’s life insurance beneficiary proceeds. She contended Primerica acted unfairly in multiple ways to create the controversy and thus the district court should not have permitted Primerica to use interpleader as a shield against her breach of contract claim. Finding no reversible error, the Eighth Circuit Court of Appeals affirmed the district court’s summary judgment order in favor of Primerica. View "Primerica Life Insurance Co. v. Reid" on Justia Law

In February 2021, the Vermont State Auditor of Accounts, Douglas Hoffer, filed a complaint alleging that defendant OneCare Accountable Care Organization, LLC, had breached various provisions in its contract with the Department for Vermont Health Access (DVHA) by denying the Auditor’s requests for OneCare’s employee payroll and benefits records for fiscal years (FY) 2019 and 2020. The civil division granted OneCare’s motion to dismiss, concluding that the Auditor lacked contractual or statutory authority to demand the records, and the Auditor appealed. After review, the Vermont Supreme Court found no reversible error and affirmed. View "Hoffer v. OneCare Accountable Care Organization, LLC, d/b/a OneCare Vermont" on Justia Law

This appeal arose from conflicting interpretations of the statutory provisions that govern the Public Employee Retirement System of Idaho (“PERSI”) and the administration of employer contributions to the Firefighters’ Retirement Fund (“FRF”). Under Idaho Code sections 59-1391 and 59-1394, a city or fire district that “employs” firefighters participating in the FRF on October 1, 1980, was considered an “employer” and required to make additional contributions to ensure the FRF remains solvent. Having employed only a single firefighter who received funds from the FRF, Kuna Rural Fire District (“KRFD”) argued it was not an employer under the code and not required to contribute to the fund because that employee retired in 1985 and received a lump-sum benefit. KRFD notified PERSI of its intent to cease contributions, but PERSI denied this request. KRFD filed a notice of appeal to the PERSI Retirement Board (“Board”). A hearing officer issued a recommended decision concluding KRFD had to continue contributing under section 59-1394. The Board adopted this decision. KRFD petitioned for judicial review under the Idaho Administrative Procedure Act (“IDAPA”) with the district court, which affirmed the Board’s decision. KRFD timely appealed to the Idaho Supreme Court. Finding no error, the Supreme Court also affirmed the Board's decision. View "Kuna Rural Fire District v. PERSI" on Justia Law

Crowley Government Services, Inc. sued the General Services Administration and its Administrator (collectively, GSA), seeking declaratory and injunctive relief to halt the GSA’s purported practice of interfering with payments owed to Crowley under its contract with the United States Transportation Command (TRANSCOM). Crowley argued the Administrative Procedure Act (APA), and the general federal question statute, 28 U.S.C. § 1331, conferred subject matter jurisdiction on the district court to review the GSA’s alleged violation of the Contract Disputes Act of 1978, and the Transportation Act of 1940. The question this case presented for the Circuit Court of Appeals for the District of Columbia's review was whether Crowley’s suit against the GSA, whichwasis not a party to Crowley’s contract with TRANSCOM, was “at its essence” contractual, including whether Crowley “in essence” sought more than $10,000 in monetary relief from the federal government such that it was subject to the exclusive jurisdiction of the United States Court of Federal Claims (Claims Court) pursuant to the Tucker Act. The district court answered affirmatively and dismissed Crowley’s complaint for lack of subject matter jurisdiction. The Court of Appeals disagreed: Crowley’s action against the GSA in district court was not “at its essence” contractual because Crowley did not seek to enforce or recover on the contract with TRANSCOM. Nor did Crowley “in essence” seek monetary relief from the federal government in district court. Rather, it requested declaratory and injunctive relief that, if granted, would have considerable value independent of (and not negligible in comparison to) any monetary recovery Crowley may ultimately attain in other proceedings. Accordingly, judgment was reversed and remanded to the district court for further proceedings. View "Crowley Government Services, Inc. v. GSA" on Justia Law