Justia Civil Procedure Opinion Summaries

The case involves a coalition of states led by Washington suing the FDA over its 2023 REMS, which eliminated in-person dispensing requirements for the abortion drug mifepristone. Washington argues that the FDA should have further reduced restrictions on the drug, claiming that the remaining requirements impose unnecessary hurdles. Idaho, leading another coalition of states, sought to intervene, arguing that the elimination of the in-person dispensing requirement would harm its interests by making the drug easier to obtain and harder to police, potentially increasing Medicaid costs and endangering maternal health and fetal life.The United States District Court for the Eastern District of Washington denied Idaho's motion to intervene. The court found that Idaho did not have a significantly protectable interest that would be impaired by the litigation, as its complaint concerned different aspects of the 2023 REMS. The court also denied permissive intervention, concluding that Idaho's claims did not share common questions of law or fact with Washington's claims.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's denial of Idaho's motion to intervene as of right. The Ninth Circuit held that Idaho must independently satisfy the requirements of Article III standing because it sought different relief from Washington. The court concluded that Idaho's complaint did not establish a cognizable injury-in-fact that was fairly traceable to the FDA's revised safe-use restrictions. Idaho's alleged economic injuries, law enforcement burdens, and quasi-sovereign interests were deemed too speculative or indirect to confer standing. The court dismissed for lack of jurisdiction the portion of the appeal concerning the denial of permissive intervention. View "STATE OF WASHINGTON V. FDA" on Justia Law

Caris MPI, Inc. (Caris) provided cancer diagnostic services to UnitedHealthcare, Inc. (United) for over ten years without a written contract. United audited Caris’s past claims and determined that Caris had used incorrect billing codes, resulting in overpayments. United began recouping these overpayments by offsetting them against new payment claims from Caris. Caris challenged United’s recoupment through United’s internal process, but after United rejected Caris’s appeals, Caris filed suit in Texas state court alleging various state law claims.United removed the case to the United States District Court for the Northern District of Texas, asserting federal officer jurisdiction under 28 U.S.C. § 1442(a)(1). The district court denied Caris’s motion to remand and dismissed Caris’s claims without prejudice, finding that Caris failed to exhaust administrative remedies under the Medicare Act.The United States Court of Appeals for the Fifth Circuit reviewed the case and agreed that federal officer jurisdiction existed. However, the court found that the district court erred in dismissing Caris’s claims for failure to exhaust administrative remedies. The Fifth Circuit held that the administrative review process under Medicare Part C does not extend to claims where an enrollee has no interest, and there were no administrative remedies for Caris to exhaust. The court distinguished this case from others by noting that no enrollee had requested an organization determination or appeal, and all enrollees had already received the services for which United sought recoupment. Consequently, the court affirmed the denial of the remand motion, reversed the dismissal of Caris’s claims, and remanded the case for further proceedings. View "Caris MPI v. UnitedHealthcare, Incorporated" on Justia Law

K.B., a patient at the Alaska Psychiatric Institute (API), has been under successive involuntary commitment orders since 2019 due to his diagnoses of schizoaffective disorder, antisocial personality disorder, and traumatic brain injury. His condition has led to violent outbursts and delusional behavior, resulting in his banishment from local shelters and hotels. In September 2022, Dr. Anthony Blanford, K.B.'s attending psychiatrist, filed another 180-day commitment petition. During the proceedings, K.B. expressed dissatisfaction with his appointed attorney, particularly over whether his trial would be by jury or bench.The Superior Court of the State of Alaska, Third Judicial District, Anchorage, initially set the trial for late September. K.B.'s attorney informed the court that K.B. had requested a jury trial. However, on the first day of jury selection, K.B. indicated he preferred a bench trial. The court allowed defense counsel to consult with K.B., who confirmed his preference for a bench trial. The next day, K.B.'s attorney reported that K.B. had fired him for not listening and reiterated his preference for a bench trial. After further consultation, the attorney confirmed K.B.'s preference for a bench trial, and the court proceeded accordingly, ultimately granting the 180-day commitment petition.The Supreme Court of the State of Alaska reviewed the case. K.B. argued that the superior court erred by not conducting a representation hearing or inquiring further into his dissatisfaction with his attorney. The Supreme Court held that the superior court was not required to delve further into the attorney-client relationship. The court found that the circumstances, viewed objectively, did not indicate a breakdown in communication or decision-making capability between K.B. and his attorney. Therefore, the superior court's order granting the 180-day commitment was affirmed. View "In re Hospitalization of K.B." on Justia Law

The case involves three sets of plaintiffs who filed class-action lawsuits against their healthcare provider, Cedars-Sinai Health System and Cedars-Sinai Medical Center. The plaintiffs alleged that Cedars-Sinai unlawfully disclosed their private medical information to third parties through tracking software on its website. Cedars-Sinai removed the suits to federal court, arguing that it developed its website while acting under a federal officer and at the direction of the federal government.The district court disagreed with Cedars-Sinai's argument. It held that Cedars-Sinai developed its website in compliance with a generally applicable and comprehensive regulatory scheme and that there is therefore no federal jurisdiction under § 1442(a)(1). The court found that although Cedars-Sinai’s website furthers the government’s broad goal of promoting access to digital health records, Cedars-Sinai’s relationship with the federal government does not establish that it acted pursuant to congressionally delegated authority to help accomplish a basic governmental task.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s orders remanding the removed actions to state court. The court agreed with the district court that Cedars-Sinai developed its website in compliance with a generally applicable and comprehensive regulatory scheme under the Health Information Technology for Economic and Clinical Health Act, and that there was therefore no federal jurisdiction under § 1442(a)(1). The court concluded that Cedars-Sinai did not meet § 1442(a)(1)’s “causal nexus” requirement. View "Doe v. Cedars-Sinai Health System" on Justia Law

This case involves a qui tam action under the False Claims Act (FCA) and the Iowa False Claims Act (IFCA) brought by Stephen Grant, a sleep medicine practitioner, against Steven Zorn, Iowa Sleep Disorders Center, and Iowa CPAP. Grant alleged that the defendants had knowingly overbilled the government for initial and established patient visits and violated the Anti-Kickback Statute and the Stark Law by knowingly soliciting and directing referrals from Iowa Sleep to Iowa CPAP. The district court found the defendants liable for submitting 1,050 false claims to the United States and the State of Iowa and imposed a total award of $7,598,991.50.The district court had rejected the defendants' public disclosure defense and awarded summary judgment to the defendants on the Anti-Kickback Statute and Stark Law claim. After a bench trial, the district court found the defendants liable on several claims, including that Iowa Sleep had violated the anti-retaliation provisions of the FCA and IFCA by firing Grant. The district court also concluded that the defendants had overbilled on initial patient visits but not on established patient visits.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed in part, vacated in part, and remanded for further proceedings. The court held that the public disclosure bar was inapplicable because Grant’s complaint did not allege “substantially the same allegations” contained in the AdvanceMed letters. The court also held that the district court did not abuse its discretion in admitting expert testimony on extrapolation and overbilling. However, the court found that the district court erred in its determination of damages and civil penalties, violating the Eighth Amendment’s Excessive Fines Clause. The court vacated the punitive sanction and remanded the case for further proceedings. View "Grant v. Zorn" on Justia Law

Joel Phillip McNinch, Jr., a dementia patient with other serious health issues, was admitted to Brandon Nursing and Rehabilitation Center, LLC in June 2019. He was later admitted to Merit Health Rankin due to combative behaviors related to his dementia. He developed a decubitus ulcer and was admitted to St. Dominic Hospital, where he died the next day. His widow, Cheryl McNinch, requested her husband's medical records from Brandon Nursing and Merit Health soon after his death and received them in mid-December 2019. She filed a complaint in January 2022, alleging negligence, medical malpractice, gross negligence, and reckless disregard, claiming that substandard care had accelerated her husband's health deterioration and led to his death.The defendants moved to dismiss the case, arguing that the action was barred by the two-year statute of limitations. Mrs. McNinch argued that the discovery rule operated to toll the statute of limitations until she received the medical records. The trial court converted the defendant’s motion to dismiss into a motion for summary judgment and granted the motion without holding a hearing.The Supreme Court of Mississippi reversed the trial court's decision, finding that the trial court erred by granting summary judgment to the defendants. The Supreme Court held that there were genuine issues of material fact regarding whether Mrs. McNinch had knowledge of negligent conduct through personal observation or other means prior to or at the time of Mr. McNinch’s death. The court found that the discovery rule could operate to toll the statute of limitations when the medical records are necessary to discover the negligence. The court concluded that Mrs. McNinch exercised reasonable diligence in requesting the medical records promptly, and therefore, the complaint was filed within the statute of limitations. The case was remanded to the circuit court for further proceedings. View "McNINCH v. BRANDON NURSING & REHABILITATION CENTER" on Justia Law

The case involves a dispute over the eligibility of a married individual, Costa Tingos, for Medicaid long-term care benefits. Costa and his wife, Mary, had been married for over 50 years, but had kept their finances largely separate due to Costa's history of gambling and financial mismanagement. When Costa moved into a nursing home, he applied for Medicaid benefits. However, Mary refused to provide information about her income and assets, which was necessary to determine Costa's eligibility. Costa argued that Mary's refusal to cooperate should not affect his eligibility.The case was initially heard by the Massachusetts Medicaid program, MassHealth, which denied Costa's application. Costa appealed to the MassHealth board of hearings, which also denied his appeal. Costa then sought judicial review in the Superior Court, which vacated the board's decision and remanded the case back to the board. After two more rounds of hearings and appeals, the Superior Court affirmed the board's decision to deny Costa's application.The Supreme Judicial Court of Massachusetts affirmed the decision of the Superior Court. The court held that the board's interpretation of the phrase "refuses to cooperate" in the relevant regulation was reasonable. The court found that Mary's refusal to disclose her financial information did not constitute a refusal to cooperate within the meaning of the regulation, given the couple's long history of cooperation in other aspects of their marriage. The court also rejected Costa's argument that the board's decision was arbitrary and capricious. View "Freiner v. Secretary of the Executive Office of Health and Human Services" on Justia Law

The case revolves around Tokvan Ly, a man suffering from severe mental illness, who was incarcerated in the Scott County Jail. The district court found Ly incompetent to face criminal proceedings and ordered him committed to the care of the appellant, Jodi Harpstead, the Commissioner of Human Services. The law requires that persons in Ly's position be prioritized for admission to state-operated treatment programs and be admitted within 48 hours. However, Ly was not admitted within this timeframe. Fifteen days after his commitment, Ly remained in jail and was not receiving the specialized treatment needed for his severe mental illness. Consequently, he filed a petition for writs of mandamus and habeas corpus, alleging that the Commissioner was failing to comply with a mandatory duty to admit him to treatment within 48 hours under the Priority Admission statute and seeking damages resulting from his delayed admission to treatment.The district court issued a peremptory writ of mandamus that determined the Commissioner’s liability solely on the facts as alleged in Ly’s petition, and set the issue of mandamus damages for a fact trial. The Commissioner appealed the district court’s order, contending that she could immediately appeal the order before entry of final judgment. The court of appeals disagreed and dismissed the appeal for lack of jurisdiction.The Minnesota Supreme Court concluded that the basis for appeal from an order issuing a peremptory writ of mandamus under Rule 103.03(g) has been extinguished, and that appeal must instead proceed from a final judgment under Minn. R. Civ. App. P. 103.03(a). The court further concluded that an order issuing a peremptory writ is not appealable under Rule 103.03(a) as a form of irregular judgment, and that the district court order currently on appeal does not satisfy the finality requirement of that rule. However, the court invoked its inherent authority and its authority under Minn. R. Civ. App. P. 102 to suspend the final judgment requirement of Rule 103.03(a), reverse the decision of the court of appeals, exercise jurisdiction over the Commissioner’s underlying appeal, and remand to the court of appeals to consider the merits of the appeal. View "Ly v. Harpstead" on Justia Law

The case involves a lawsuit filed by Rosemary Lambert and Carolyn Hinzman, individually and as co-executors of the estate of Delmar P. Fields, against Eldercare of Jackson County, LLC, Community Health Association, and Dr. Irvin John Snyder. The plaintiffs allege that Mr. Fields contracted COVID-19 while a resident at Eldercare and died while under the care of Jackson General and Dr. Snyder. The defendants sought dismissal of the lawsuit, arguing that they were immune from liability under the COVID-19 Jobs Protection Act.The Circuit Court of Jackson County denied the defendants' motions to dismiss. The court interpreted the term "actual malice" in the COVID-19 Jobs Protection Act to mean that the defendant acted with the intent to injure or harm the plaintiff or decedent. The court found that the plaintiffs had alleged sufficient facts to survive a motion to dismiss.On appeal, the Supreme Court of Appeals of West Virginia affirmed the lower court's decision in part and reversed in part. The court held that the term "actual malice" in the COVID-19 Jobs Protection Act means that the defendant acted with the deliberate intent to commit an injury, as evidenced by external circumstances. The court found that the plaintiffs had alleged sufficient facts to show that Eldercare engaged in intentional conduct with actual malice. However, the court found that the allegations against Jackson General Hospital and Dr. Snyder were insufficient to establish that they engaged in intentional conduct with actual malice. The case was remanded for further proceedings. View "Eldercare of Jackson County, LLC v. Lambert" on Justia Law

Nicole Costin, individually and on behalf of her minor son, filed a lawsuit against Glens Falls Hospital and several of its staff members. Costin alleged that the hospital discriminated against her due to her substance-abuse disorder, violating the Americans with Disabilities Act and the Rehabilitation Act. She also raised state-law claims. Costin's allegations included the hospital conducting drug tests without informed consent, reporting her to the New York State Child Abuse and Maltreatment Register based on a false positive drug test, withholding pain relief, accelerating her labor without consent, and refusing to correct their actions.The United States District Court for the Northern District of New York dismissed Costin’s action, concluding that she failed to plausibly allege that she was discriminated against due to her disability. The district court also declined to exercise supplemental jurisdiction over her state-law claims.The United States Court of Appeals for the Second Circuit affirmed in part, vacated in part, and remanded the case for further proceedings. The court agreed with the lower court's dismissal of Costin’s claims related to the denial of an epidural, acceleration of labor, and treatment of her newborn. However, the court disagreed with the dismissal of Costin’s claims related to the hospital's instigation of a Child Protective Services investigation and its administration of a drug test. The court found that Costin had plausibly alleged that these actions were based on discriminatory policies, not medical decisions. The court also vacated the lower court's decision to decline supplemental jurisdiction over Costin’s state-law claims. View "Costin v. Glens Falls Hospital" on Justia Law