Justia Health Law Opinion Summaries

Plaintiffs, several nursing homes approved by the Iowa Department of Human Services (DHS) as Medicaid providers, submitted annual reports disclosing their income and expenses to DHS. DHS used the reports to calculate the Medicaid per diem reimbursement rates for the nursing homes. Some of the facilities' expenses were disallowed by DHS, and DHS reduced reimbursement rates accordingly. The facilities appealed the adjustments. The director of human services upheld the action. The district court affirmed. The court of appeals reversed, concluding that the DHS rules did not support its decision that the disputed costs were not allowable. The Supreme Court affirmed, holding that DHS's exclusion of the facilities' lab, x-ray, and prescription drug costs from the nursing homes' reports was based on an incorrect interpretation of its rules. View "Sunrise Ret. Cmty. v. Iowa Dep't of Human Servs." on Justia Law

The Iowa Board of Nursing and Iowa Department of Public Health (collectively, Defendants) enacted rules allowing advanced registered nurse practitioners (ARNPs) to supervise radiologic technologists using fluoroscopy machines. Several physician associates brought this action against Defendants to invalidate the rules. Two nursing associations intervened to defend the rules. The district court invalidated the rules, concluding that Defendants exceeded their authority in promulgating the rules. The Supreme Court reversed, holding (1) the Board's application of law to fact was not irrational, illogical, or wholly unjustifiable; (2) the rules fell within the authority of the Board and Department; and (3) the other challenges to the rules failed. Remanded. View "Iowa Med. Soc'y v. Iowa Bd. of Nursing" on Justia Law

Appellant pleaded guilty to first-degree harassment. While Appellant was incarcerated for the offense, the State sought to have him committed as a sexually violent predator (SVP) under Iowa Code 229A. A jury found Appellant was an SVP, and Appellant was ordered for commitment. The Supreme Court remanded the case. On retrial, the jury against concluded Appellant was an SVP, and Appellant was again ordered committed. The Supreme Court affirmed, holding (1) Appellant failed to meet his burden to show by a preponderance of the evidence that he was prejudiced by his counsel's advise to sign a speedy trial waiver; (2) Appellant was not prejudiced by his trial counsel's failure to adequately argue the trial should have been bifurcated to protect Appellant's due process rights; and (3) the prosecution did not misstate the evidence during trial. View "In re Detention of Blaise" on Justia Law

After Defendant was twice arrested and convicted of sexual offenses, proceedings were commenced for Defendant's commitment as a sexually violent predator. After a jury trial, Defendant was committed to the Civil Commitment Unit for Sexual Offenders (CCUSO). In 2010, Defendant submitted a petition seeking a final hearing on whether he should be discharged from the CCUSO or placed in a transitional release program. Thereafter, the State submitted its notice of annual review for 2011 asserting there was no evidence of any change in Defendant's mental abnormality constituting a ground for his discharge. Defendant subsequently filed a petition requesting a final hearing on his 2011 annual review and his claims for either discharge or placement in the transitional release program. The district court concluded Defendant failed to demonstrate by a preponderance of the evidence that he was entitled to a final hearing on either discharge or placement in a transitional release program. The Supreme Court affirmed, holding that the district court did not err in its judgment. View "Taft v. Dist. Court" on Justia Law

Respondent was incarcerated with an approaching release when the State filed a petition alleging Respondent was a sexually violent predator (SVP) under Iowa's civil commitment statute. After a jury trial, Respondent was found to be an SVP. The primary issue on appeal was whether the State properly waited until the conclusion of Respondent's overall prison term to bring an SVP proceeding, when Respondent received consecutive sentences for a sexual abuse offense and a burglary/arson offense, with the sentence for burglary/arson to be served after the sentence for the sexual abuse offense. The Supreme Court reversed, holding (1) a person receiving consecutive sentences, one of which is for a sexually violent offense, is "presently confined" within the meaning of the civil commitment statute, and thus, an SVP petition is timely filed if it is filed before the respondent's anticipated release from prison, as long as the current term of imprisonment includes a sentence for a sexually violent offense; (2) sufficient evidence supported the jury's verdict that Respondent was an SVP; but (3) it was error to admit expert testimony on the State's procedure for selecting persons against whom SVP proceedings are filed. View "In re Detention of Stenzel" on Justia Law

After Appellant's emergency hospitalization, a district court concluded that B.B. was seriously mentally impaired. Appellant was subsequently involuntarily committed. During the pendency of the appeal, Appellant was released to outpatient treatment at the University of Nebraska Medical Center (UNMC). Because the court file indicated Appellant was no longer a patient at UNMC, the State filed a motion to discharge and terminate the proceedings. The district court granted the motion, terminated the proceedings, and discharged Appellant from court-ordered treatment and placement. At issue on appeal was whether Appellant's appeal was moot when Appellant had been released and the proceedings terminated. The Supreme Court affirmed the judgment of the district court, holding (1) this appeal was not moot, as a person adjudicated seriously mentally impaired and involuntarily committed suffers adverse collateral consequences; and (2) substantial evidence supported the conclusion that Appellant was seriously mentally impaired. View "In re B.B." on Justia Law

In this putative class action, Plaintiffs were doctors of chiropractic who alleged they had been victimized by the discriminatory practices of Iowa's largest health insurer, Wellmark, Inc. The district court (1) granted Wellmark's motion to dismiss claims brought under Iowa's insurance regulatory statutes because no private cause of action was provided therein; (2) granted Wellmark's motion for summary judgment on Plaintiffs' antitrust claims based on the "state action" exemption found in Iowa Code 553.6(4); (3) granted summary judgment on claims alleging Wellmark breached its obligations under a judicially approved national class action settlement in Love v. Blue Cross Blue Shield Ass'n; and (4) granted summary judgment on several specific antitrust claims. The Supreme Court (1) reversed in part, holding that the district court erred in granting summary judgment on Plaintiffs' antitrust claims based on the state action exemption, as the record failed to establish the challenged conduct fell within the exemption; and (2) otherwise affirmed. Remanded. View "Mueller v. Wellmark, Inc." on Justia Law

In this case, the Supreme Court was asked to review a summary judgment ruling dismissing a wrongful death action because it was commenced later than is allowed under Iowa Code 614.1(9), a statute of repose limiting the time allowed for commencing medical negligence cases. Plaintiffs contended their case should not have been dismissed because Defendants fraudulently concealed the fact that a tissue specimen harvested from Plaintiffs' decedent more than six years before the filing of this action was not evaluated by a board-certified pathologist. In the alternative, Plaintiff contended the continuum-of-negligent-treatment doctrine precluded the summary dismissal of this case notwithstanding the statute of repose. The Supreme Court affirmed, holding (1) section 614.1(9) in this case operated to extinguish the decedent's cause of action even before she and her husband knew it had accrued; and (2) under the the circumstances, the fraudulent-concealment doctrine and the continuum-of-negligent-treatment doctrine did not preserve Plaintiffs' causes of action, and section 614.1(9) denied Plaintiffs a remedy for negligent acts or omissions occurring more than six years prior to the commencement of this action. View "Estate of Anderson v. Iowa Dermatology Clinic, PLC" on Justia Law

Plaintiffs sued a surgeon, alleging negligent performance of a pancreaticoduodenectomy, and a hospital, contending it negligently granted credentials to the surgeon. The district court entered judgment in favor of Defendants after concluding that the tort of negligent credentialing was a viable claim in Iowa. Plaintiffs appealed, contending the district court applied the wrong standard of care in adjudicating Plaintiffs' claim of negligent credentialing against the hospital. The Supreme Court affirmed, holding (1) the district court applied the standard of care advocated by Plaintiffs; and (2) substantial evidence supported the district court's conclusion that the hospital did not breach the standard of care. View "Hall v. Jennie Edmundson Memorial Hosp." on Justia Law

In this case, the Supreme Court considered whether an internal audit created by Broadlawns Medical Center as a result of the theft of drugs by an employee was a public record under the Iowa Open Records Act. The district court concluded that, because the internal audit was provided to the Iowa Board of Pharmacy in order to assist in its investigation of licensing matters arising from the theft, the internal audit amounted to investigative materials in the hands of a licensing board under Iowa Code 272C.6(4) and was not subject to disclosure. The Supreme Court (1) reversed the judgment of the district court holding that the internal audit was not subject to disclosure, as the internal pharmacy audit was a public record, not a confidential record, and other statutory exceptions asserted to prevent public disclosure were inapplicable; and (2) affirmed the rulings of the district court that the plaintiff failed to establish the basis for nondisclosure under Iowa Code 22.7(61). View "Hall v. Broadlawns Med. Ctr." on Justia Law