Younger Abstention in Medicaid 1983 case

The federal district court of Kansas refused to consider the merits of the claim of a Medicaid beneficiary under 42 U.S.C. § 1983 that she was improperly denied Medicaid. The court dismissed the case on Younger abstention grounds, Younger v. Harris, 401 U.S. 37 (1971), because the beneficiary had begun but not exhausted her state administrative remedies. The court characterized the termination of Medicaid benefits as a state law “enforcement effort designed to address violations of state Medicaid law.” The court acknowledged that the Supreme Court has held that a plaintiff is generally not required to exhaust state remedies before bringing a claim under section 1983, but held that because the state administrative proceeding “was fundamentally coercive in nature,” the plaintiff had to fully pursue appellate remedies within the state judicial system before bringing her section 1983 action in federal court. Brown v. Day, 477 F.Supp.2d 1110 (D.Kan. Feb. 28, 2007).

The plaintiff is a developmentally disabled adult who resides at a private residential care facility.  When her mother died, the plaintiff became a beneficiary of a residuary trust which gave the trustee discretion to distribute income to pay for the plaintiff’s support and maintenance.  The substantive question was whether the trust counted as an available resource.  The plaintiff requested an administrative hearing, which she won, but the state agency’s final decision reinstated the termination of benefits.  The plaintiff did not pursue a further appeal to state court but rather initiated federal court action under section 1983.

 

The court decision fails to cite Medicaid or federal benefit cases.  Instead, the court compared the case to precedent involving a preacher cited in state court proceedings for violating a city noise ordinance, Moore v. City of Asheville, 396 F.3d 385 (4th Cir. 2005), and the state court system for issuing parking tickets, O’Neill v. City of Phildelphia, 32 F.3d 785 (3d Cir. 1994).  The court noted that, under relevant precedent, if the state administrative proceeding was “remedial,” then exhaustion was not required but if the state administrative proceeding was “coercive,” then exhaustion would be required.  The court stated:

 

At first blush, it might appear that the administrative proceeding was remedial because it sought to “remedy” the allegedly wrongful decision to terminate benefits.  This conclusion has superficial appeal, but it ignores the coercive nature of the state action which triggered plaintiff’s right to request an administrative hearing.  Under Kansas law, the termination of benefits to ineligible recipients is an enforcement mechanism designed to address violations of state Medicaid law.

 

Thus, the court characterized the beneficiary as a violator of state law.  The administrative hearing process was not viewed under the prism of the beneficiary’s due process rights, but instead the court characterized the administrative hearing “as part of the state’s overall law enforcement scheme.” 

 

The decision admits that the result is far from mandated by precedent.  “The Court concedes that this is a difficult question, and that without binding Tenth Circuit precedent, reasonable minds could disagree with this conclusion.”

The court stated that plaintiff could have avoided this outcome “by either exhausting state remedies before bringing Section 1983 claims to federal court or bringing such claims straight to federal court before initiating state administrative proceedings.”