Two Courts Say Medicaid Statute Is Enforceable

[This article was originally published on June 1, 2001.  The links were updated on August 16, 2018.]

Two U.S. District Courts have rejected the Eastern District of Michigan's ruling that private individuals who believe they are not receiving proper benefits under their state's Medicaid program cannot sue state officials. This is good news for anyone receiving or considering receiving Medicaid nursing home benefits.

The Michigan court had ruled that the Supremacy Clause - the constitutional principle that federal statutes are the supreme law of the land - does not apply to programs like Medicaid. Westside Mothers v. Haveman 133 F. Supp. 2d 549 (E.D. Mich. 2001). The Medicaid program, the Michigan judge said, is merely a contract between two governments - the federal government and the state. Medicaid recipients, he said, have no right to sue to enforce the contract, even if they believe the state is not giving them benefits called for in federal law. See "Federal Judge Bars Medicaid Suits Against States".

But in Boudreau v. Ryan, No. 00-5392-011.MEV (N.D. Ill. May 1, 2001), the U.S. District Court for the Northern District of Illinois rejects the findings in Westside Mothers virtually point by point. The case involves a claim that the state violated federal Medicaid laws by denying services to developmentally disabled Medicaid recipients. The Boudreau court does not share the argument advanced by the Michigan court that legislation like Medicaid is not covered by the Supremacy Clause. The court points to a number of instances where the Supreme Court struck down state laws or regulations in cases involving federal welfare benefits.

The Boudreau court also refuses to see the plaintiffs as simply seeking to enforce a contract between the state and federal government, viewing the case instead as a suit against state officers who are violating federal law. The court finds the provisions of the Medicaid statute enforceable under 42 U.S.C. § 1983, which creates a federal cause of action for violation of rights secured by the federal laws and the Constitution. The court's ruling in Boudreau can be downloaded by going to https://www.clearinghouse.net/chDocs/public/PB-IL-0002-0010.pdf.

In the second case, Antrican v. Buell, No. 00-CV-173(h)(4) (E.D.N.C.Apr. 17, 2001), Medicaid recipients sued the state, claiming that the state's low reimbursement rates for dentists effectively prevented them from receiving dental services. The U.S. District Court for the Eastern District of North Carolina finds that most of the Medicaid recipients' claims are enforceable under Section 1983.

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