Justia Health Law Opinion SummariesArticles Posted in Minnesota Supreme Court
Buzzell v. Walz
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
In re Schmalz
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
In re Appeal by RS Eden
The Supreme Court reversed the decision of the Commissioner of Human Services determining that RS Eden, a supervised living facility where J.W. received treatment before voluntarily leaving and dying of a drug overdose five days later, was responsible for maltreatment of J.W. by neglect, holding that the Commission's decision was not supported by substantial evidence.RS Eden appealed the maltreatment determination to the court of appeals, which affirmed. The Supreme Court reversed, holding that that Commissioner's finding of maltreatment for neglect for RS Eden's failure to obtain a waiver or to confer with a prescribing physicians was not supported by substantial evidence because RS Eden complied with the rules regarding the disposition of controlled substances and took reasonable steps to protect its client. View "In re Appeal by RS Eden" on Justia Law
Linn v. BCBSM, Inc.
Appellant BCBSM, Inc. (“Blue Cross”) denied respondent James Linn’s insurance claim because the requested treatment was not considered medically necessary under the parties’ health-plan contract. After Blue Cross denied the claim, an external-review entity determined that the treatment was, in fact, medically necessary for Linn’s condition. Blue Cross paid the claim, but Linn and his wife sued Blue Cross for breach of contract. The district court granted summary judgment for Blue Cross, concluding that the treatment was not medically necessary under the contract’s plain terms and that Blue Cross fulfilled its contractual obligations when it paid for the treatment following the external review. The court of appeals reversed. Because the Minnesota Supreme Court concluded: (1) external-review decisions were independent determinations of medical necessity that did not supersede contractual definitions of medical necessity; and (2) the health-plan contract plainly excluded coverage for Linn’s claim for treatment, the Court reversed. View "Linn v. BCBSM, Inc." on Justia Law
In re Consolidated Hosp. Surcharge Appeals of Gillette Children’s Specialty Healthcare
The Minnesota Department of Human Services (DHS) assessed surcharges against seven hospitals and hospital systems (collectively, the Hospitals) on their net patient revenue under Minn. Stat. 256.957(2). The Hospitals appealed their surcharge assessments for various months, alleging that federal law preempted the surcharge to the extent it required them to pay a surcharge on revenues obtained from insurance carriers that participated in the Federal Employee Health Benefits Program and the TRICARE program. The Commissioner of DHS denied the claim. The court of appeals affirmed. The Supreme Court affirmed, holding that the surcharge was not preempted by federal law. View "In re Consolidated Hosp. Surcharge Appeals of Gillette Children’s Specialty Healthcare" on Justia Law
Binkley v. Allina Health System
Kirk Lloyd sought to be admitted at United Hospital to stop his pattern of self-harm. United informed Lloyd and his mother, Melinda Binkley, that Lloyd would not be admitted to United’s inpatient mental-health program and released Lloyd. The next night, Lloyd committed suicide. Binkley, acting as trustee, filed a medical-malpractice action against Allina Health System and its staff (collectively, Respondents) alleging that Respondents’ negligent failure to properly examine, evaluate, and provide services to Lloyd caused his death. Respondents filed a motion for summary judgment, arguing that they were entitled to immunity for their good-faith actions under the Minnesota Commitment and Treatment Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Respondents’ good-faith decision to deny Lloyd admission to the inpatient mental health unit is entitled to immunity; but (2) it is not clear that Respondents are entitled to summary judgment on all of Binkley’s claims. Remanded. View "Binkley v. Allina Health System" on Justia Law
A.A.A. v. Dep’t of Human Servs.
Appellant in this case was a nine-year-old boy with severe autism, epilepsy, and chronic seizures. The Commissioner of the Minnesota Department of Human Services (DHS) found that Appellant was not dependent in "mobility" and therefore reduced his authorized personal care assistant (PCA) services covered through the Minnesota Medical Assistance program. The district court reversed the Commissioner's decision, concluding that Minn. Stat. 256B.0659 did not require Appellant to be physically incapable of mobility to be eligible for covered services. The court of appeals reversed because Appellant was physically able to begin and complete moving from place to place without assistance. At issue was whether a person who is physically able to move without assistance but lacks the ability to direct his movement to a specific location has a dependency in mobility under the statute. The Supreme Court affirmed, holding that the Commissioner's interpretation of the statute was supported by the plain and ordinary meaning of "mobility." View "A.A.A. v. Dep't of Human Servs." on Justia Law
Coker v. Jesson
In 2000, Appellant was indeterminately committed as a sexual dangerous person as a result of a series of sex offenses involving teenage girls. Appellant later petitioned for provisional discharge from civil commitment. After weighing the evidence presented by Appellant and the Commissioner of Human Services at a first-phase hearing, the Supreme Court Judicial Appeal Panel dismissed Appellant's petition under Minn. R. Civ. P. 41.02(b). The court of appeals affirmed. The Supreme Court reversed, holding that the Appeal Panel committed reversible error in applying Rule 41.02(b) by failing to view the evidence produced at the first-phase hearing in a light most favorable to Appellant and by weighing the evidence produced during the first phase of the hearing. Remanded. View "Coker v. Jesson" on Justia Law
Park Nicollet Clinic v. Hamann
In 2004, Doctor informed Employer, a medical clinic, that he planned to exercise his rights under Employer's policy that rewarded length of service by giving benefits to physicians who were sixty years old or older and had at least fifteen years of taking night calls. Doctor agreed to postpone exercising his rights under the policy until the next year. In 2005, Employer told Doctor that the policy no longer existed. Doctor later withdrew from taking night call. As a result, Employer reduced Doctor's salary. In 2009, sued Employer for breach of contract and promissory estoppel, claiming Employer breached the policy by refusing to allow him to be exempt from night call without salary reduction. The district court granted Employer's motion to dismiss, holding that the two-year statute of limitations began to run in 2005 when Employer informed Doctor it would not honor its obligations under the policy. The court of appeals reversed, concluding that a new cause of action accrued each time a payment was due but not paid. The Supreme Court reversed, holding that Doctor's cause of action accrued, and the statute of limitations began to run, in 2005, and therefore, Doctor's claim was barred by the statute of limitations.
Bearder v. State
The Minnesota Department of Health, as part of its newborn screening program, collected blood samples of newborn children to test for various disorders. The Department retained the excess blood samples for other uses and allowed outside research organizations to use them to conduct health studies. Nine families (Appellants) sued the State and the Department (Appellees), arguing that the Department violated the Genetic Privacy Act by collecting, using, storing, and disseminating the children's blood samples and test results without obtaining written informed consent. The district court granted summary judgment in favor of Appellees, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the blood samples collected and stored by the Department were genetic information subject to the restrictions of the Genetic Privacy Act; and (2) the newborn screening statutes provided an express exception to the Genetic Privacy Act only to the extent that the Department was authorized to administer newborn screening by testing the samples for disorders and to store the test results, and the newborn screening statutes did not expressly authorize the Department to collect, use, store, or disseminate the blood samples for any other use without written consent.