Justia Health Law Opinion Summaries

The case revolves around Tokvan Ly, a man suffering from severe mental illness, who was incarcerated in the Scott County Jail. The district court found Ly incompetent to face criminal proceedings and ordered him committed to the care of the appellant, Jodi Harpstead, the Commissioner of Human Services. The law requires that persons in Ly's position be prioritized for admission to state-operated treatment programs and be admitted within 48 hours. However, Ly was not admitted within this timeframe. Fifteen days after his commitment, Ly remained in jail and was not receiving the specialized treatment needed for his severe mental illness. Consequently, he filed a petition for writs of mandamus and habeas corpus, alleging that the Commissioner was failing to comply with a mandatory duty to admit him to treatment within 48 hours under the Priority Admission statute and seeking damages resulting from his delayed admission to treatment.The district court issued a peremptory writ of mandamus that determined the Commissioner’s liability solely on the facts as alleged in Ly’s petition, and set the issue of mandamus damages for a fact trial. The Commissioner appealed the district court’s order, contending that she could immediately appeal the order before entry of final judgment. The court of appeals disagreed and dismissed the appeal for lack of jurisdiction.The Minnesota Supreme Court concluded that the basis for appeal from an order issuing a peremptory writ of mandamus under Rule 103.03(g) has been extinguished, and that appeal must instead proceed from a final judgment under Minn. R. Civ. App. P. 103.03(a). The court further concluded that an order issuing a peremptory writ is not appealable under Rule 103.03(a) as a form of irregular judgment, and that the district court order currently on appeal does not satisfy the finality requirement of that rule. However, the court invoked its inherent authority and its authority under Minn. R. Civ. App. P. 102 to suspend the final judgment requirement of Rule 103.03(a), reverse the decision of the court of appeals, exercise jurisdiction over the Commissioner’s underlying appeal, and remand to the court of appeals to consider the merits of the appeal. View "Ly v. Harpstead" on Justia Law

The case involves a wrongful death claim filed by Judith Rygwall, the mother of Amy Rygwall, against ACR Homes, Inc. Amy, a profoundly vulnerable woman with intellectual and physical disabilities, was under the care of ACR Homes. On New Year's Eve 2015, Amy aspirated (inhaled food into her lungs) and began showing signs of respiratory distress. A member of ACR's staff was informed of these signs but did not seek immediate emergency care for Amy. Instead, she searched online for an urgent care clinic that accepted Amy's insurance with the shortest wait time. Amy's condition worsened, and she died 13 days later from related complications. Rygwall filed a wrongful-death action, asserting that ACR should have immediately called 911 upon learning of Amy's respiratory distress and that failure to do so caused Amy's death.ACR moved for summary judgment on the issue of causation. The district court granted ACR's motion, and the court of appeals affirmed. The district court concluded that Rygwall did not establish that Amy would not have died even if she had received emergency care soon after she exhibited respiratory distress and aspirated after lunch at Rise. The court of appeals agreed, reasoning that Rygwall's expert's report did not explain how Amy's treatment would have progressed had she been seen sooner or how immediate treatment would have prevented her condition from becoming fatal.The Supreme Court of Minnesota reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. The Supreme Court held that Rygwall raised a genuine issue of material fact as to whether ACR caused her daughter's death. The court concluded that based on the record, a reasonable jury could find in Rygwall's favor on the issue of causation, and therefore summary judgment for ACR was inappropriate. View "Rygwall vs. ACR Homes, Inc." on Justia Law

The Minnesota Supreme Court affirmed the convictions of Gregory Paul Ulrich for first-degree premeditated murder, attempted first-degree premeditated murder, and discharge of an explosive or incendiary device. Ulrich had targeted the Allina Health clinic in Wright County, where he had been treated, because he was dissatisfied with his medical care and blamed the clinic for his chronic pain. He had recorded videos threatening the clinic, purchased a gun and supplies for making pipe bombs, and then carried out an attack at the clinic, shooting several people and detonating three pipe bombs. On appeal, Ulrich argued that the lower court had abused its discretion by denying his motions to strike a juror for cause and to change the venue, and that the evidence was insufficient to support his convictions. The Supreme Court ruled that the lower court had not abused its discretion because the juror had not expressed actual bias requiring either rehabilitation or removal, and because Ulrich had not renewed his motion to change the venue after voir dire, thereby forfeiting his right to contest the denial of his motion. The Supreme Court also ruled that the evidence was sufficient to support the convictions because it supported a reasonable inference that Ulrich had planned the attack and believed that it would cause the victims' deaths. View "State v. Ulrich" on Justia Law

In a dispute with the Department of Human Services (DHS) in Minnesota, Nobility Home Health Care, Inc. (Nobility) was found to have violated Minnesota Statutes section 256B.064 and Minnesota Rule 9505.2165 by failing to maintain health service records as required by law and by submitting claims for services for which underlying health service records were inadequate. The Minnesota Supreme Court held that such conduct constitutes "abuse" under the statute, even if there was no intent to deceive the DHS. However, the court declined to interpret or apply the phrase "improperly paid... as a result of" abuse in the statute, which governs the grounds for monetary recovery. The court reversed the decision of the court of appeals and remanded the case to the DHS for further analysis of this issue. The court's decision means that DHS's demand for an overpayment for Nobility’s first-time paperwork errors may not be reversed unless the DHS also establishes that the provider was improperly paid because of that abuse. View "In the Matter of SIRS Appeal by Nobility Home Health Care, Inc" on Justia Law

The Minnesota Supreme Court ruled that an individual can bring a private action under the Minnesota private attorney general statute to compel a healthcare provider to disclose that individual’s medical records as required by the Minnesota Health Records Act. This decision was based on the interpretation of the private attorney general statute, which the court concluded applies to laws regarding unfair, discriminatory, and other unlawful practices in business, commerce, or trade. The court found that the Minnesota Health Records Act, which mandates the timely disclosure of health records to patients, falls within this category. However, the court also held that an individual does not have a private right of action under the Minnesota Health Care Bill of Rights to compel a healthcare provider to disclose an individual’s medical records. The ruling affirmed in part, reversed in part, and remanded the case to the district court for further proceedings. View "Findling vs. Group Health Plan, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the final order of the Commissioner of the Department of Human Services' (DHS) concluding that Trinity had engaged in the abuse outlined in DHS's notices and spreadsheets, holding that the first report of the administrative law judge (ALJ) was the binding decision in this matter.Trinity Home Health Care, which provided nursing and personal care assistant services, received reimbursement from DHS for services that it provided to Medicaid-eligible people with disabilities. After an investigation, DHS sent Trinity notices of termination from the program and demanding return of overpayments and payment-withholding. Both before and after remand by the Commissioner, the ALJ found that terminating Trinity's participation in the Minnesota Health Care Programs was an inappropriate sanction for Trinity's failure to provide certain records. The Commissioner modified the report, concluding that Trinity had engaged in the abuse alleged by the DHS. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Commissioner did not have the authority to remand the case due to the DHS's general authority to administer and supervise Medicaid; and (2) the Commissioner did not have implied authority to remand the case to the ALJ under case law. View "In re Surveillance & Integrity Review Appeals by Trinity Home Health Care Services" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court concluding that federal regulations implementing the federal Health Insurance Portability and Accountability Act (HIPAA) is a "specific authorization in law" under Minn. Stat. 144.293, subd. 2(2), holding that the court of appeals did not err.After Children's Health Care informed Appellants that their child's protected health information was disclosed to Children's institutionally-related foundation and its business associate for fundraising purposes Appellants sued, arguing that Children's violated the Minnesota Health Records Act, Minn. Stat. 144.291-.298. The district court granted summary judgment for Children's, concluding that the disclosure of the patient's health information was specifically authorized in law by federal regulations implementing HIPAA. The court of appeals affirmed. The Supreme Court affirmed, holding that the disclosure of the health information at issue was permitted by a "specific authorization in law," as that phrase is used in the Minnesota Health Records Act. View "Schneider v. Children's Health Care" on Justia Law

In this dispute over Governor Walz's declaration of a peacetime emergency under the Emergency Management Act, Minn. Stat. 12.01-.61, and the executive order the Governor issued requiring that Minnesotans wear face coverings, the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals dismissing the appeal as moot, holding that one issue on appeal met a mootness exception.Plaintiffs brought the underlying petition for a writ of quo warranto challenging the face-covering mandate, arguing that the Governor overstepped his powers under the Emergency Management Act and that the mask mandate violated several of their constitutional rights. The district court granted Defendants' motion to dismiss. While Plaintiffs' appeal was pending, the peacetime emergency and mask mandate ended. Consequently, the court of appeals dismissed the appeal as moot. The Supreme Court reversed in part, holding (1) the legal question of whether the Act authorizes a peacetime emergency for a public health emergency is functionally justiciable and an important issue of statewide significance that should be decided immediately; and (2) Plaintiffs' remaining challenges to the mask mandate did not meet any of the mootness exceptions. View "Snell v. Walz" on Justia Law

The Supreme Court reversed the decision of the court of appeals and remanded this case, holding that, for property to be commandeered, the government must exercise exclusive control over or obtain exclusive possession of the property such that the government could physically use it for an emergency management purpose.Appellant brought this suit arguing that his hospitality businesses were commandeered when the Governor issued emergency executive orders in response to the COVID-19 pandemic that imposed capacity limits for dining beginning in March 2020. As the owner of the commandeered property, Appellant argued, he was entitled to just compensation for the government's use under Minn. Stat. 12.34. The district court dismissed the commandeering claim, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the government exercises exclusive physical control or exclusive possession of private property when only the government may exercise control or possession of the property and the owner is denied all control over or possession of the property; and (2) remand to the district court for further proceedings was required in this case. View "Buzzell v. Walz" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the order of the district court that non-homestead life estates should not be included in Marvin Schmalz's assets, holding that the term "individual" in Minn. Stat. 256B.056, subd. 4a applies only to the applicant for medical assistance.Esther Schmalz was living at a long-term-care facility when she submitted an application for medical assistance for long-term-care benefits. As part of the assessment of her husband Marvin's assets, Renville County Human Services (RCHS) included Marvin's portion of several non-homestead life estate interests that he and Esther owned. Esther appealed, arguing that the life estates should not be included in the total amount of assets that Marvin may retain. The human services judge concluded that RCHS properly denied Esther's application for medical assistance based on the inclusion of the life estate assets owned by Marvin. The Commissioner of Minnesota Department of Human Services adopted the human services judge's recommendation. The district court concluded that the non-homestead life estates should not be included in Marvin's assets, ruling that the term "individual" in section 256B.056, subd. 4a included Marvin. The Supreme Court reversed, holding that an "individual" in the statute refers to the medical assistance applicant and not a community spouse. View "In re Schmalz" on Justia Law