Justia Health Law Opinion Summaries

The appellant was previously convicted of multiple serious offenses, including attempted murder, grand larceny of a vehicle, and three counts of first-degree murder, for which he received a death sentence and additional prison terms. Decades later, federal habeas relief was granted on the basis of ineffective assistance of counsel regarding his insanity defense, resulting in the vacatur of his conviction and sentence. Upon the State’s attempt to retry him, a competency evaluation found him incompetent to stand trial. The criminal complaint was dismissed without prejudice, and the State sought his civil commitment based on evidence that he has a mental disorder and poses a danger to himself and others.Following a hearing, the Eleventh Judicial District Court of Pershing County found clear and convincing evidence supporting civil commitment and ordered the appellant to a forensic mental health facility, to remain until he either qualifies for conditional release or reaches the statutory maximum duration for such commitment. The appellant argued that he should be credited for the time he spent in prison under the vacated conviction, citing NRS 176.055, and also contended that the civil commitment should not exceed ten years. The district court rejected these arguments, determining that credit for time served under NRS 176.055 does not apply to civil commitments, as such credit is limited to sentences imposed for criminal convictions.The Supreme Court of Nevada affirmed the district court’s order. The court held that Nevada’s statutory scheme does not allow credit for time served in prison under a vacated criminal judgment to be applied against the duration of civil commitment, as civil commitment is a preventive and treatment-oriented measure rather than punitive. The court further held that NRS 178.463 does not provide credit in this context, as it applies only to time spent on conditional release, which the appellant has not received. View "Rogers v. State of Nevada" on Justia Law

G.H. was a child with serious, complex medical issues requiring extensive treatment. In 2011, his older sister died from a mitochondrial disorder. Afterward, G.H. began showing symptoms believed to be similar, and his mother, J.S.H., sought care for him at Boston Children's Hospital. Dr. Alice Newton, head of the hospital’s child protection team and a mandated reporter, filed a report with the Massachusetts Department of Children and Families (DCF) alleging medical child abuse by J.S.H., based on perceived inconsistencies in reported symptoms. The report was unsubstantiated, and subsequent similar reports from other sources were also unsubstantiated. In 2013, Dr. Newton moved to Massachusetts General Hospital (MGH). In 2018, after learning J.S.H. was identified as a witness in an unrelated trial, Dr. Newton reviewed G.H.’s medical records at MGH and again raised concerns of medical child abuse, documenting her findings and filing another report with DCF, which was also deemed unsubstantiated.J.S.H. filed suit in the United States District Court for the District of Massachusetts against Dr. Newton and MGH, asserting state-law emotional distress claims and a federal disability discrimination claim under Section 504 of the Rehabilitation Act. The district court granted summary judgment in favor of the defendants, finding insufficient evidence to proceed to trial. The court declined to consider an affidavit submitted by J.S.H. on the grounds of untimeliness.The United States Court of Appeals for the First Circuit reviewed the district court’s summary judgment de novo. The appellate court held that expert testimony was required to establish negligence for the emotional distress claims but was not provided. The court further found no evidence that Dr. Newton’s actions constituted extreme and outrageous conduct or caused harm to G.H., nor evidence that MGH denied or limited services to G.H. based on disability. The First Circuit affirmed the district court’s grant of summary judgment to both defendants. View "J.S.H. v. Newton" on Justia Law

The Missouri General Assembly enacted two statutes effective August 28, 2023: the SAFE Act, which generally prohibits health care providers from performing gender transition surgeries or prescribing cross-sex hormones and puberty-blocking drugs for minors, and the Medicaid ban, which precludes MO HealthNet payments for such treatments when used for gender transition. The statutes include specific exemptions, such as for treatment of certain medical conditions and for minors already receiving such care prior to enactment. E.N., on behalf of her minor child and joined by medical professionals and organizations, challenged both laws, alleging violations of equal protection, due process, and the gains of industry clause under the Missouri Constitution.The Circuit Court of Cole County conducted a two-week bench trial and entered judgment in favor of the State, upholding the constitutionality of both statutes. The court found the challengers had raised only facial challenges and determined that neither statute violated the constitutional provisions cited. The challengers appealed, raising multiple points of error regarding the constitutional analysis and factual findings at trial.The Supreme Court of Missouri reviewed the circuit court’s determination de novo, applying a presumption of constitutionality. Relying on recent decisions from the United States Supreme Court and the United States Court of Appeals for the Eighth Circuit, the court held that both statutes classify based only on age and medical use, not on sex or transgender status. Thus, rational-basis review applied. The court found that the statutes are rationally related to legitimate state interests, such as safeguarding minors and managing public resources, and do not infringe fundamental rights. The court affirmed the circuit court’s judgment, concluding that the challengers failed to demonstrate any constitutional violation. View "E.N. v. Kehoe" on Justia Law

Amanda Ann Soron, who was unhoused, gave birth outdoors in freezing temperatures behind a retail store. Police discovered her with her newborn, who was still attached by the umbilical cord and subsequently pronounced dead at the hospital. Greenwood Village Police Officer Moreno accompanied Soron in the ambulance and remained present during her treatment, recording procedures and statements with a body-worn camera and documenting evidence during her hospital stay. Four months after the incident, Soron was arrested and charged with child abuse resulting in death. The prosecution sought and obtained a court order for production of all medical records related to Soron and her child’s hospital stay.In the Arapahoe County District Court, Soron moved to prevent the prosecution from accessing her medical records, arguing they were protected by the physician-patient privilege and that the request for records was misleading. After a period during which Soron was found incompetent and later restored to competency, the trial court ruled in her favor. The court found that the child abuse exception to the physician-patient privilege only applied to testimony, not to documents, and that the medical records—including those captured on Officer Moreno’s body-worn camera—were privileged. The court ordered the medical records and camera footage to be sealed and preserved, and denied Soron’s request for a veracity hearing as moot.The Supreme Court of Colorado reviewed the suppression order on interlocutory appeal. It affirmed the trial court’s decision that Soron’s medical records are protected by the physician-patient privilege and that the child abuse exception does not extend to documentary evidence. However, the Supreme Court reversed the portion of the order sealing the body-worn camera footage and related notes, remanding for further factual findings to determine whether that material is privileged or subject to other policy considerations. View "People v. Soron" on Justia Law

Ridgeline Medical, LLC provided medical services to David Lyon and sought to recover $777 in unpaid charges. Ridgeline sent a final billing statement to Lyon at his provided address, but Lyon did not receive it and did not pay. Ridgeline retained a law firm to collect the debt, which sent demand letters to the same address, also not received by Lyon. Subsequently, Ridgeline initiated a lawsuit for breach of an implied-in-fact contract and reported Lyon’s debt to a consumer reporting agency. Lyon responded by alleging Ridgeline’s actions violated the Idaho Patient Act (IPA) and counterclaimed for statutory penalties under the Act, asserting noncompliance with its procedural requirements.The Magistrate Court for Bonneville County initially found some IPA provisions unconstitutional, severed them, and dismissed Ridgeline’s complaint for noncompliance with the remaining requirements. It denied Lyon’s claim for statutory penalties, finding that provision violated the Eighth Amendment as applied. The Idaho Attorney General intervened to defend the Act’s constitutionality. After further briefing and argument, the magistrate court vacated its prior decision, held the IPA constitutional in full, dismissed Ridgeline’s complaint again, and awarded statutory penalties to Lyon. On intermediate appeal, the District Court of the Seventh Judicial District affirmed the magistrate court’s amended decision.On further appeal, the Supreme Court of the State of Idaho reviewed the magistrate court’s decision independently, with due regard for the district court’s ruling. The Supreme Court held that the challenged IPA provisions regulate commercial speech and are subject to intermediate scrutiny, which they satisfy. The court found no violation of the First Amendment (speech or petition), Fourteenth Amendment (equal protection or due process), or Eighth Amendment. The Supreme Court affirmed the district court’s decision, upholding the IPA against Ridgeline’s constitutional challenges. Neither party was awarded attorney fees on appeal. View "Ridgeline Medical, LLC v. Lyon" on Justia Law

Indiana amended its laws in 2022 to prohibit and criminalize the use of telehealth and telemedicine for abortions, requiring that abortion-inducing drugs be dispensed and consumed in person by a physician in a hospital or qualified surgical center. The Satanic Temple, a Massachusetts-based religious nonprofit, operates a telehealth abortion clinic serving only patients in New Mexico but seeks to extend these services to its Indiana members. It does not run, nor intends to operate, an in-person abortion clinic in Indiana or maintain ties to Indiana hospitals or surgical centers. The Temple filed suit against the Indiana Attorney General and Marion County Prosecutor, seeking to enjoin enforcement of the criminal statute (§ 16-34-2-7(a)) and to obtain declaratory relief under Indiana’s Religious Freedom Restoration Act.The United States District Court for the Southern District of Indiana reviewed the case and granted the defendants’ motion to dismiss for lack of standing. The court found that the Satanic Temple failed to identify any specific member who suffered an injury from the challenged law, thus lacking associational standing. It also held that the Temple itself lacked standing, as it could not show an injury in fact and could not demonstrate that favorable relief would redress its alleged harms due to other Indiana laws independently barring its intended conduct.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The Seventh Circuit held that the Satanic Temple lacked both associational and individual standing. The Temple failed to identify a specific injured member and relied only on statistical probabilities and generalized claims of stigmatic injury, which were insufficient. Additionally, the Temple did not present concrete plans to violate the law, and even if § 16-34-2-7(a) were enjoined, other statutes would independently prevent its telehealth abortion services in Indiana. Thus, the Seventh Circuit affirmed the dismissal for lack of subject matter jurisdiction. View "Satanic Temple, Inc. v Rokita" on Justia Law

In 2023, Wyoming enacted two laws restricting abortion: the Life is a Human Right Act, which broadly banned abortion procedures with limited exceptions, and a separate statute prohibiting the prescription or use of drugs to induce abortions, also with exceptions. These laws imposed criminal and civil penalties on violators, excluding the pregnant person. After the laws took effect, several plaintiffs—including medical professionals, non-profit organizations, and an individual woman—challenged the statutes in District Court of Teton County, arguing they violated Article 1, Section 38 of the Wyoming Constitution, which guarantees each competent adult the right to make their own health care decisions.The district court granted summary judgment in favor of the plaintiffs, finding that the challenged laws unreasonably and unnecessarily infringed on the constitutional right to make health care decisions, and issued a permanent injunction preventing enforcement of the abortion restrictions. The State of Wyoming appealed directly to the Wyoming Supreme Court.The Wyoming Supreme Court, exercising de novo review, held that the decision to terminate or continue a pregnancy is a health care decision protected by Article 1, Section 38. The Court determined that this provision confers a fundamental right, and that statutes restricting it must satisfy strict scrutiny: the State must show such laws are narrowly tailored to achieve a compelling governmental interest and use the least restrictive means. The majority found that the State failed to present sufficient evidence that the abortion restrictions and their exceptions were the least restrictive means of protecting prenatal life. Accordingly, the Wyoming Supreme Court affirmed the district court’s ruling, holding the 2023 abortion laws unconstitutional under the Wyoming Constitution. View "State of Wyoming v. Johnson" on Justia Law

A healthcare clinic and several physicians providing abortion services in North Dakota challenged the constitutionality of N.D.C.C. ch. 12.1-19.1, a law criminalizing most abortions with certain exceptions. The plaintiffs argued that the statute was unconstitutionally vague regarding when abortions could be performed to preserve the life or health of a pregnant woman. They asserted that the law's language failed to provide clear guidance to physicians about permissible conduct, especially given the severe criminal penalties for violations. Testimony from medical experts detailed the unpredictable and rapidly evolving risks that pregnancy can pose to a mother's health, and highlighted the difficulties in interpreting the statutory terms such as “serious health risk,” “substantial physical impairment,” and “major bodily function.”The District Court of Burleigh County, South Central Judicial District, granted summary judgment for the plaintiffs. The court found that the statute was impermissibly vague, concluding that its unclear language chilled physicians from providing constitutionally protected medical care. The court also determined that the law infringed on pregnant women’s fundamental rights under the North Dakota Constitution and was not narrowly tailored to promote health or protect life. As a result, the court declared N.D.C.C. ch. 12.1-19.1 unconstitutional and void.On appeal, the Supreme Court of North Dakota reviewed the district court’s judgment. The justices issued separate opinions, but did not reach the four-member majority required by the state constitution to declare a legislative enactment unconstitutional. Therefore, the effect was that the district court’s judgment was reversed, and N.D.C.C. ch. 12.1-19.1 was not declared unconstitutional. The main holding is that, due to the lack of a sufficient majority, the abortion law was not invalidated and the lower court's judgment was reversed. View "Access Independent Health Services, Inc. v. Wrigley" on Justia Law

Max and Peggy Lancaster transferred approximately $3.8 million in property to a family LLC owned by their adult children, receiving a promissory note and other loan-related documents in exchange. They subsequently applied for Medicaid benefits in Oklahoma but were found ineligible due to their financial resources exceeding Medicaid’s asset limit. The Lancasters challenged this determination in federal court, arguing that the Oklahoma Department of Human Services and the Oklahoma Health Care Authority violated 42 U.S.C. § 1396a(a)(8) of the Medicaid Act, which requires prompt provision of benefits to eligible individuals. They sued under 42 U.S.C. § 1983, contending that the Agencies’ asset calculation was erroneous and deprived them of a federally protected right.The United States District Court for the Western District of Oklahoma granted the Agencies’ motion to dismiss. The court found that the promissory note received from the LLC was a countable resource under state law and not a bona fide loan. As a result, the court concluded the Lancasters were not eligible for Medicaid benefits because their assets exceeded the threshold set by law. The Lancasters appealed this decision to the United States Court of Appeals for the Tenth Circuit.While the appeal was pending, the Supreme Court decided Medina v. Planned Parenthood South Atlantic, which clarified the standard for determining whether provisions of the Medicaid Act confer individually enforceable rights under § 1983. The Tenth Circuit held that, under Medina, 42 U.S.C. § 1396a(a)(8) does not clearly and unambiguously confer a private right enforceable via § 1983. Therefore, the court affirmed the district court’s dismissal of the Lancasters’ claims, holding that there is no individually enforceable right under § 1396a(a)(8) for the purposes of this lawsuit. View "Lancaster v. Cartmell" on Justia Law

Kevin Clay and his associate founded a pharmaceutical sales company that marketed compounded prescriptions directly to patients, promising them a share of the insurance reimbursements for each prescription filled. The company partnered with a pharmacy willing to pay a portion of the insurance proceeds and recruited employees from a local business whose health plan covered these prescriptions. Patients were directed to a doctor who readily prescribed the creams, resulting in millions of dollars in reimbursements over two years. Clay established a public charity to reduce his tax burden but used its funds for personal expenses and failed to comply with nonprofit requirements.The United States District Court for the Northern District of Ohio oversaw Clay’s trial. A jury convicted him of conspiracy to commit healthcare fraud, healthcare fraud, and making a false statement to the IRS, but acquitted him of a separate tax charge. The court sentenced Clay to 51 months’ imprisonment and ordered restitution totaling nearly $7 million to both Fiat Chrysler and the IRS. Clay appealed his convictions, sentence, and restitution orders.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed Clay’s convictions and rejected his challenges to the jury instructions and evidentiary rulings. However, it found error in the district court’s restitution orders and the application of a sentencing enhancement. Specifically, the Sixth Circuit held that restitution should not include payments for medically necessary prescriptions and that the apportionment of restitution must consider each defendant’s contribution and economic circumstances. The court also determined the restitution order to the IRS was not properly substantiated and included acquitted conduct. Finally, the case was remanded for further proceedings on restitution and for clarification or reconsideration of the leadership sentencing enhancement. View "United States v. Clay" on Justia Law