Justia Health Law Opinion Summaries

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

A patient was admitted to a hospital for liver disease and, while in an altered mental state, fell while accompanied by a caregiver. She suffered a fractured hip, requiring surgery, and was later discharged. The patient filed a negligence lawsuit against the hospital, alleging a failure to prevent or appropriately respond to her fall. During discovery, she requested all incident reports related to her fall. The hospital identified an Incident Report and a Root Cause Analysis but refused to produce them, invoking federal and state privileges that protect certain internal analyses and reports of medical errors.The McCracken Circuit Court ordered the hospital to produce the Incident Report and to provide the Root Cause Analysis with redactions for portions covered by federal privilege. The trial court found that the Incident Report and parts of the Root Cause Analysis contained factual information not otherwise available in the patient's medical records and ruled that such information should be discoverable. The Court of Appeals reviewed the trial court's order after the hospital sought a writ of prohibition. It held that the Incident Report was not privileged under federal or state law but concluded the Root Cause Analysis was fully protected by federal privilege, even its factual portions, and thus could not be disclosed.Upon review, the Supreme Court of Kentucky affirmed the Court of Appeals. The court held that the federal Patient Safety and Quality Improvement Act privilege protected the entire Root Cause Analysis from disclosure, with no exception for factual information within the document. However, it held that the Incident Report was not protected by either the federal or state privileges because it was generated in compliance with regulatory obligations, not as part of the hospital's privileged peer review or patient safety evaluation system. As a result, the Incident Report was discoverable, while the Root Cause Analysis was not. View "BAPTIST HEALTHCARE SYSTEM, INC. V. KITCHEN" on Justia Law

The case centers on Kristal Glover-Wing, who founded and operated Angel Care Hospice (ACH) in Louisiana, a Medicare-certified hospice provider. ACH’s business model involved recruiting local physicians as medical directors who referred patients and certified them as terminally ill, even when evidence showed many patients maintained active lifestyles inconsistent with terminal illness. Glover-Wing instructed staff to emphasize patients’ worst conditions in records and resisted discharging patients who no longer qualified, sometimes directing staff to falsify records or reenroll patients after hospitalizations. An investigation revealed that, for at least twenty-four patients, hospice services were provided and Medicare reimbursed ACH over $1.5 million, despite the patients not meeting eligibility criteria.Following a whistleblower complaint and investigation, a federal grand jury in the United States District Court for the Western District of Louisiana indicted Glover-Wing and two physicians for conspiracy to commit healthcare fraud and three counts of healthcare fraud. During trial, the jury asked if the conspiracy charge could include ACH employees as coconspirators, leading to a dispute over jury instructions. Glover-Wing requested judicial estoppel to prevent the government from expanding the conspiracy beyond named defendants, arguing she relied on prior government representations. The district court denied her requests, and the jury convicted Glover-Wing on all counts while acquitting the physicians. Post-trial, the district court denied Glover-Wing’s motions for acquittal and a new trial.The United States Court of Appeals for the Fifth Circuit reviewed Glover-Wing’s sufficiency-of-evidence and judicial estoppel claims. The court held that sufficient evidence supported all convictions, as a rational jury could find Glover-Wing knowingly participated in fraud and conspiracy. It further held that judicial estoppel did not apply because the government’s positions were not plainly inconsistent, nor accepted by the court, and Glover-Wing failed to show unfair detriment. The Fifth Circuit affirmed the district court’s judgment. View "United States v. Glover-Wing" on Justia Law

Congress enacted a law in 2025 that withholds Medicaid funding for one year from certain abortion providers that meet four criteria, which in effect covers most Planned Parenthood affiliates and two other organizations. The statute also withholds funding from subsidiaries, successors, clinics, and “affiliates” of such entities, even if those affiliates do not themselves meet all four criteria. Some Planned Parenthood entities qualified for defunding under the law (“Qualifying Members”), while others did not (“Non-Qualifying Members”), but the latter still risked losing funding due to the ambiguous “affiliate” provision. Concerned about the impact on their ability to provide healthcare, Planned Parenthood Federation of America, a Qualifying Member, and a Non-Qualifying Member sued to enjoin enforcement, alleging the law was an unconstitutional bill of attainder, imposed unconstitutional conditions on their right of association, and violated equal protection.The United States District Court for the District of Massachusetts granted a temporary restraining order and then preliminary injunctions, finding that the plaintiffs were likely to succeed on all three claims. The court reasoned that the law punished Planned Parenthood in violation of the Bill of Attainder Clause, impermissibly conditioned Medicaid funding on disassociation from other affiliates in violation of the First Amendment, and failed equal protection review because it targeted Planned Parenthood for its associations. The government appealed these orders.The United States Court of Appeals for the First Circuit vacated the district court’s orders. The court held that the statute did not inflict punishment as understood in bill of attainder case law, but instead established new conditions prospectively on Medicaid funding. The court also held that the “affiliate” provision is best read to cover only entities under common corporate control, avoiding constitutional problems, and thus does not burden associational rights. Finally, the court found that the law is subject only to rational basis review and is rationally related to Congress’s objectives. The preliminary injunctions were vacated and the case remanded. View "Planned Parenthood Federation of America, Inc. v. Kennedy" on Justia Law

Troy Williams pleaded guilty to various federal offenses, including drug trafficking, firearm possession by a felon, and money laundering, and was sentenced to 198 months in prison, which was below the applicable sentencing guideline range. Williams has a history of serious medical conditions—thrombophilia and recurrent deep vein thrombosis—that require ongoing management, including regular blood testing and medication. Nearly ten years into his sentence, Williams sought compassionate release, asserting that inadequate medical care at his current facility placed him at risk of severe health complications or death.After Williams filed his pro se motion for compassionate release in the United States District Court for the Northern District of Ohio, counsel was appointed to supplement his arguments. Williams claimed the Bureau of Prisons was not providing sufficient medical care, particularly after his transfer to FCI Coleman, where he alleged infrequent blood testing and interruptions in medication. He also argued the sentencing factors under 18 U.S.C. § 3553(a) favored his release. The district court reviewed his medical records and expert testimony from the prison’s clinical director, ultimately finding that Williams’s care was not so deficient as to amount to extraordinary and compelling circumstances. The district court further concluded that, even if such circumstances were present, the sentencing factors did not support early release. Williams timely appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial for abuse of discretion, considering legal questions de novo and factual findings for clear error. The Sixth Circuit held that the district court did not clearly err in finding that Williams’s medical care was adequate and that his situation did not present extraordinary and compelling circumstances under the relevant Sentencing Commission policy statement. Accordingly, the Sixth Circuit affirmed the denial of Williams’s motion for compassionate release. View "United States v. Williams" on Justia Law