Justia Health Law Opinion Summaries

The consolidated appeals in this case involved a dispute between the Secretary of Health and Human Services and a group of Maine hospitals about certain payments - called disproportionate share payments (DSH payments) - the hospitals had received in reimbursement from the federal government for charity care for fiscal years dating as far back as 1993. Generally speaking, the more low-income patients a hospital services, the higher the hospital’s DSH payment. In this case, the Secretary maintained that the Hospitals were overinclusive in their DSH payment calculations. An intermediary reassessed the DSH payments and recouped from the Hospitals approximately $22 million in alleged overpayments. The Provider Reimbursement Review Board, in turn, ordered the intermediary to restore approximately $17 million to the Hospitals. The Secretary reversed. The Hospitals sought judicial review, but neither side was satisfied with the district court’s ruling. On appeal, the First Circuit reversed in part and affirmed in part, holding (1) the Secretary properly reopened the disputed years and adequately demonstrated that the Hospitals had received substantial overpayments of DSH funds; and (2) the Hospitals’ defenses to repayment were unavailing. View "Maine Medical Center v. Burwell" on Justia Law

Appellant was civilly committed as a sexually dangerous person. When a forensic psychologist concluded that Appellant was no longer sexually dangerous, Appellant moved for a hearing to determine whether he satisfied the criteria for release under the Adam Walsh Child Protection and Safety Act. After a hearing, the district court concluded that Appellant remained sexually dangerous and, thus, subject to continued civil commitment. At issue on appeal was whether the government or the committed person bears the burden of proof at a release hearing held pursuant to 18 U.S.C. 4247(h). The First Circuit affirmed, holding (1) the burden of proof rests on the committed person to show by a preponderance of the evidence that he has achieved the capacity to safely reenter the community; and (2) in this case, Appellant failed to carry his burden of proof. View "United States v. Wetmore" on Justia Law

Under Part A of the Ryan White Comprehensive AIDS Resources Emergency Act the U.S. Department of Health and Human Services (HHS) disburses funding to combat HIV/AIDS infection in metropolitan areas that are home to more than a specified number of individuals who have AIDS. When HHS determined that the Ponce metropolitan area no longer had enough AIDS cases to qualify for continued Part A funding, Ponce and several community health groups brought this lawsuit claiming that HHS had unfairly drawn the boundaries of Ponce’s metropolitan area too narrowly. The district court concluded that HHS acted arbitrarily and capriciously in defining the “metropolitan area” of Ponce and that HHS’s methodology for defining metropolitan areas in Puerto Rico was unfair and discriminatory. The First Circuit reversed, holding that Congress could reasonably be said to have told HHS to use the boundaries that it used in defining the Ponce metropolitan area. Remanded for entry of judgment in favor of Defendants dismissing the complaint with prejudice. View "Municipio Autonomo de Ponce v. U.S. Office of Mgmt." on Justia Law

Plaintiffs filed a second amended complaint against Defendant, a medical doctor, alleging claims based on medical negligence, Defendant’s failure to obtain informed consent, and battery. The district court granted summary judgment in favor of Defendant as to the medical battery claim. After a trial as to Plaintiffs’ informed consent claim, the jury returned a verdict for Defendant. The First Circuit affirmed in part and vacated and remanded in part, holding (1) the district court properly dismissed Plaintiffs’ battery claim; but (2) the district court erred by excluding expert testimony that a fine-needle aspiration biopsy was a viable non-surgical alternative to a surgical biopsy. View "Bradley v. Sugarbaker" on Justia Law

Defendant, Plaintiff’s co-worker at a mental health facility in Norton, Massachusetts, issued an order, pursuant to Mass. Gen. Laws ch. 123, 12, authorizing Plaintiff to be seized from her home and brought to a hospital for a psychiatric evaluation, certifying that there was a “very substantial risk” that Plaintiff would injure herself. Pursuant to that order, the police took Plaintiff from her home and drove her to the hospital. A doctor at the hospital determined that Plaintiff was lucid and released her. Plaintiff subsequently brought a 42 U.S.C. 1983 claim against Defendant. The district court dismissed Plaintiff’s claim for failure to state a claim that Defendant had violated Plaintiff’s federal constitutional rights. The First Circuit affirmed, holding that Plaintiff failed to state a plausible claim for relief. View "Durand v. Harpold" on Justia Law