Justia Health Law Opinion Summaries
Sujan v. UHS Corona
A physician who practiced at Corona Regional Medical Center alleged that the hospital and three individual doctors conspired to defame him, destroy his professional reputation, and summarily suspended his admitting privileges under false pretenses. He claimed these actions were motivated by competitive and financial interests, and that the hospital and defendants orchestrated a campaign using fabricated internal reports to target him, resulting in financial and emotional harm. The physician entered into an agreement with the hospital to lift his suspension, subject to several conditions, and avoided having the suspension reported to the California Medical Board. His wife separately claimed loss of consortium due to the defendants’ actions.The Superior Court of Riverside County reviewed the case and granted summary judgment for the defendants. The court found that the physician had failed to exhaust the administrative remedies available to him through the hospital’s peer review process before suing for damages. The trial court also partially granted the defendants’ motion for attorney fees based on a provision in the hospital’s bylaws, but denied fees against the wife, and reduced the fee amounts for certain attorneys.The Court of Appeal of the State of California, Fourth Appellate District, Division Two, affirmed the judgment and the postjudgment order. The court held that the physician did not establish he was excused from exhausting his administrative remedies, as the agreement to lift his suspension was conditional and did not provide the maximum relief available through the peer review process. The court also upheld the attorney fee award to defendants under the bylaws, finding the fee provision valid and not preempted by statute, and concluded that the trial court correctly denied fees against the wife and for certain attorney billing records. View "Sujan v. UHS Corona" on Justia Law
Jensen v. Minn. Bd. of Medical Practice
During the COVID-19 pandemic, Dr. Scott Jensen, a physician and former Minnesota state senator, publicly voiced opposition to vaccine mandates and business closures. As a Republican candidate for governor in 2022, he became the subject of 18 complaints alleging he spread misinformation and endangered public health. The Minnesota Board of Medical Practice initiated four investigations, each requiring Jensen to respond and cooperate fully, including providing documents and hiring legal counsel. One investigation lasted over a year and demanded an in-person conference. Jensen claims these investigations caused him to spend substantial time and money, self-censor his public statements, and decline speaking engagements due to fear of professional repercussions.The United States District Court for the District of Minnesota dismissed Jensen’s amended complaint for lack of standing, finding his allegations “too conclusory” and lacking specific instances of chilled speech or imminent enforcement threats. The court determined he did not demonstrate injury sufficient to invoke federal jurisdiction, thus preventing further review of his constitutional claims seeking damages and injunctive relief.The United States Court of Appeals for the Eighth Circuit reviewed the dismissal. It found that Jensen’s general factual allegations of time, money spent, and self-censorship—the chilling effect—were sufficient to establish standing at the pleading stage. The court concluded that both monetary harms and reasonable self-censorship due to credible threats of enforcement constituted concrete and particularized injuries. The appellate court held that Jensen had standing to pursue his claims for damages and injunctive relief. The judgment of the district court was reversed and the case remanded for further proceedings on the merits. View "Jensen v. Minn. Bd. of Medical Practice" on Justia Law
CEDAR PARK ASSEMBLY OF GOD OF KIRKLAND, WASHINGTON V. KUDERER
A church in Washington State challenged the validity of two state laws: the Reproductive Parity Act, which requires health insurance carriers to include coverage for all federally approved contraceptives and, if maternity care is covered, for abortions; and a longstanding conscience statute, which allows employers to object to purchasing coverage for specific healthcare services on religious or moral grounds. The church, as an employer providing health insurance to its employees, argued that these laws forced it to provide, pay for, or facilitate access to abortion and certain contraceptives in violation of its religious beliefs and right to religious autonomy.The United States District Court for the Western District of Washington found that the church had standing to sue, but granted summary judgment in favor of the state defendants on the merits, concluding that the challenged laws did not violate the Free Exercise Clause or church autonomy doctrine. Both sides appealed. Previously, the Ninth Circuit vacated the district court’s judgment for lack of standing, but after the Supreme Court’s decision in Diamond Alternative Energy, LLC v. EPA, 606 U.S. 100 (2025), it vacated its own opinion and reheard the case.The United States Court of Appeals for the Ninth Circuit held that the church had Article III standing, as the laws caused it to facilitate abortion indirectly. Assuming, without deciding, that the laws burdened the church’s religious exercise, the court concluded that the laws are neutral and generally applicable. Therefore, rational basis review applied, and the church conceded the laws met that standard. The court affirmed summary judgment for the state defendants, holding that the laws do not violate the Free Exercise Clause or the church autonomy doctrine. View "CEDAR PARK ASSEMBLY OF GOD OF KIRKLAND, WASHINGTON V. KUDERER" on Justia Law
In re Necessity for the Hospitalization of Derius L.
A man with a lengthy history of severe mental illness, homelessness, and repeated hospitalizations was admitted multiple times to the Alaska Psychiatric Institute (API), most recently seeking shelter during winter. He has diagnoses including schizoaffective disorder, traumatic brain injury, and polysubstance dependence, and has frequently been barred from local shelters and facilities due to his behavior. After his admission in early 2024, API staff observed his acute psychosis, noncompliance with outpatient treatment, and declining condition. There was discussion of a possible discharge plan involving relocation to live with family in Arizona, but concerns were raised about his ability to safely travel, the sufficiency of supports available there, and his own reluctance to leave Alaska.The Superior Court of the State of Alaska, Third Judicial District, Anchorage, first granted a 30-day involuntary commitment and authorization for administration of psychotropic medication, then later extended the commitment for 90 days. At the 90-day hearing, testimony indicated that less restrictive alternatives, including discharge to family, were considered but not feasible at that time. The court also approved a renewed petition for involuntary medication after finding that the man lacked the capacity to make informed medical decisions and had not previously, while competent, expressed a clear wish to refuse such medication. The man did not file timely objections to the master’s findings.The Supreme Court of the State of Alaska reviewed the case under the plain error standard, given the absence of objections below. The court held that while it was a clear error for the superior court to proceed without confirming whether the man was advised of the option for voluntary treatment, this mistake was not obviously prejudicial because the record indicated he would not have accepted voluntary admission. The Supreme Court also found no plain error in the lower court’s conclusions that no less restrictive alternative was available and that the requirements for involuntary medication were satisfied. The superior court’s orders were affirmed. View "In re Necessity for the Hospitalization of Derius L." on Justia Law
Posted in:
Alaska Supreme Court, Health Law
Kuehn v. Pillen
An individual Nebraska resident, voter, and taxpayer sought declaratory and injunctive relief challenging the constitutionality of two medical cannabis laws enacted by voter-approved initiatives in the November 2024 general election. He named as defendants the Governor, other state officials, members of the Nebraska Medical Cannabis Commission, and the sponsors of the initiatives. The plaintiff alleged the laws violated the federal Supremacy Clause, improperly delegated regulatory authority in violation of Nebraska’s separation of powers, and were otherwise unconstitutional. He further claimed public officials and agencies would expend state funds and resources to implement these laws, and that this expenditure was unlawful.Previously, before the laws passed, the same individual brought a preelection challenge to the legal sufficiency of the initiative petitions in the District Court for Lancaster County. That challenge was rejected, and the Nebraska Supreme Court affirmed. After the election, he filed a new action in the same district court, seeking to enjoin the Governor from certifying the measures. The district court denied his request for a temporary restraining order. Once the laws were certified and enacted, he amended his complaint several times, ultimately alleging taxpayer standing, standing for a matter of great public concern, and standing under a Nebraska statute governing initiative challenges. The defendants moved to dismiss, contending he lacked standing.The Nebraska Supreme Court reviewed the district court’s dismissal de novo. The Supreme Court held that the plaintiff lacked standing to bring the suit. Specifically, it concluded he did not have taxpayer standing, as his allegations of incidental expenditures and government employee time spent implementing the laws did not amount to illegal expenditures sufficient to confer standing under Nebraska law. The Court also found he did not qualify for any exception for matters of great public concern. The order dismissing his complaint without prejudice was affirmed. View "Kuehn v. Pillen" on Justia Law
Edwards v. Witherspoon
While incarcerated at a North Carolina women’s correctional facility, the plaintiff learned she was pregnant and, due to her history of opioid use disorder, was prescribed medication for opioid withdrawal (MOUD) under a prison policy that restricted such treatment to pregnant inmates. When she went into labor, she was transported to the hospital and was shackled at various stages during labor, delivery, and her return to prison. After giving birth, the facility denied her further MOUD because she was no longer pregnant, instead providing a short course of alternative pain medication. She experienced significant withdrawal symptoms as a result. The plaintiff brought claims against various prison officials, alleging violations of the Eighth Amendment for the shackling and for denial of MOUD, as well as disability discrimination under the Americans with Disabilities Act and the Rehabilitation Act.The United States District Court for the Eastern District of North Carolina granted summary judgment to all defendants, finding no constitutional violations and that qualified immunity protected the officials. It also concluded that the plaintiff was not discriminated against under federal disability law because the MOUD program was limited to pregnant inmates.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed in part, vacated in part, and remanded. The Fourth Circuit held that, as to certain officials, there was a genuine dispute of fact regarding whether shackling the plaintiff during labor and postpartum, without evidence of a security or flight risk, violated the Eighth Amendment. The court also held that the denial of MOUD following pregnancy, pursuant to a categorical policy, could constitute deliberate indifference to serious medical needs under the Eighth Amendment, and that summary judgment was inappropriate for the medical officials involved. The court further vacated the lower court’s disposition of the plaintiff’s ADA and Rehabilitation Act claims, remanding for further proceedings. Summary judgment for other defendants was affirmed. View "Edwards v. Witherspoon" on Justia Law
ADOM V. CALIFORNIA DEPARTMENT OF CORRECTIONS AND REHABILITATION
An individual incarcerated at a California state prison suffers from a spinal condition causing severe pain and limited mobility, and also experiences incontinence. For nearly a year, prison staff provided him with adult diapers as a medical accommodation. However, after a transfer to a different housing unit, his access to these supplies was abruptly terminated, and his requests for reinstatement were denied for almost five months. During this period, he was forced to soil himself and his environment, resulting in humiliation and distress, despite repeated written and verbal requests for accommodation.He filed a lawsuit in the United States District Court for the Northern District of California, alleging violations of the Americans with Disabilities Act (ADA) and the Eighth Amendment. The district court granted summary judgment in favor of the California Department of Corrections and Rehabilitation (CDCR) and other defendants, concluding he was not entitled to relief under the ADA because it found no evidence of discrimination due to his disability and determined his claims for injunctive relief were moot once supplies were reinstated.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s summary judgment as to the ADA claim. The appellate court held that a reasonable jury could find the plaintiff is disabled under the ADA due to his spinal condition and incontinence, that he was denied meaningful access to toileting and hygiene services because of his disabilities, and that this denial was because of his disabilities. The court further found there was sufficient evidence to create a triable issue as to whether CDCR acted with deliberate indifference, a necessary element for damages. The panel also clarified that a public entity is not excused from ADA obligations merely because an accommodation is not deemed medically necessary. The case was remanded for further proceedings, including consideration of standing for injunctive relief. View "ADOM V. CALIFORNIA DEPARTMENT OF CORRECTIONS AND REHABILITATION" on Justia Law
Vertex Pharmaceuticals Inc. v. HHS
A biotechnology company developed a gene therapy for two hereditary blood disorders, which may negatively affect patients’ fertility. To address potential deterrence due to fertility concerns, the company created a program offering up to $70,000 for fertility services to patients receiving the therapy. The program was initially limited to privately insured patients, as the company was concerned it might violate federal healthcare statutes if extended to federally insured patients. To clarify the legality, the company requested an advisory opinion from the Department of Health and Human Services (HHS), arguing that the program did not violate relevant statutes and, alternatively, qualified for statutory exceptions.After significant delays and exchanges, HHS issued an unfavorable advisory opinion, concluding the program violated both the Anti-Kickback Statute (AKS) and the Beneficiary Inducement Statute (BIS), and denied immunity from enforcement. The company sued HHS and its officials in the United States District Court for the District of Columbia, challenging both the advisory opinion and the regulations governing timing for advisory opinions. The district court granted summary judgment to HHS, finding that the program violated the AKS and deferring to HHS’s reasoning regarding the BIS exception, while dismissing the challenge to the timing regulations as moot after the opinion was issued.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the district court’s decision de novo. The court affirmed summary judgment for HHS regarding the AKS, holding that the program constituted prohibited remuneration intended to induce patients to purchase the therapy. However, it reversed as to the BIS, finding HHS’s determination arbitrary and capricious due to its failure to explain why the statutory exception did not apply. The court also held that the company had standing to challenge HHS’s timing regulations and that those regulations unlawfully evaded the statutory deadline. The judgment was affirmed in part, reversed in part, and remanded. View "Vertex Pharmaceuticals Inc. v. HHS" on Justia Law
State v. Cook
A woman brought her nearly two-year-old son to a hospital in Lincoln, Nebraska, where he was found with multiple injuries, including bruises, swelling, and a fractured leg. Subsequent medical examinations revealed further injuries, such as broken ribs, a lung contusion, brain swelling, and ultimately, the child died from his injuries. The mother, who had left the child in the care of her boyfriend and others, admitted to noticing symptoms and injuries over a period of weeks but did not seek medical care, citing reasons such as believing the injury was minor and fear of involvement with Child Protective Services. Evidence at trial included interviews, witness testimony, text messages, and internet searches indicating the mother was aware of the child’s worsening condition.The District Court for Lancaster County reviewed the case and presided over a jury trial. The jury found the mother guilty of intentional child abuse resulting in death, intentional child abuse resulting in serious bodily injury, and possession with intent to deliver or delivery of a controlled substance near a school. The court denied pretrial motions to exclude certain photographic evidence and sentenced her to consecutive prison terms totaling 70 years to life for the most serious charges, and additional years for the drug offense.The Nebraska Supreme Court examined claims of insufficient evidence, improper admission of photographs, ineffective assistance of counsel, and excessive sentencing. Applying the appropriate standards of review, the court held that there was sufficient evidence for the convictions, the photographs were relevant and not unduly prejudicial, and the sentences were within statutory limits and not an abuse of discretion. Claims of ineffective assistance were rejected as either unsupported or not prejudicial. The court affirmed the judgment of the district court. View "State v. Cook" on Justia Law
Knighten v. VitalCore Health Strategies, LLC
A healthcare administrator at a Mississippi correctional facility, who had served in that role for many years, was employed by a new contractor after it obtained the healthcare services contract for the facility. The administrator became concerned that a prison physician was providing inadequate care and might be impaired by drugs, reporting these concerns to her employer and recommending the physician’s termination. Despite those reports, the physician remained employed after a brief administrative leave. Later, the administrator was notified her employment would be terminated because the employer required all administrators to be registered nurses, and she did not meet that requirement.After her termination, the administrator filed suit in the Sunflower County Circuit Court, alleging wrongful termination and tortious interference. She argued her firing was due to her refusal to participate in denying adequate medical care and her repeated reports about the physician’s performance and possible drug use. The employer denied these allegations, and moved for summary judgment, asserting that she was an at-will employee and had not reported conduct subject to criminal penalties as required under the public-policy exceptions recognized in McArn v. Allied Bruce-Terminix Co., Inc. The circuit court granted summary judgment for the employer, finding that her claims did not implicate criminal conduct and thus did not fall within McArn’s exceptions.The Supreme Court of Mississippi reviewed the case de novo. It held that the administrator failed to show a genuine issue of material fact that she was discharged for refusal to participate in or for reporting criminal conduct, as required under McArn. The Court further clarified that Swindol v. Aurora Flight Sciences Corp. did not expand McArn beyond criminal conduct. Accordingly, the Supreme Court of Mississippi affirmed the circuit court’s grant of summary judgment in favor of the employer. View "Knighten v. VitalCore Health Strategies, LLC" on Justia Law