Justia Health Law Opinion Summaries

Alicia Rae Pufahl applied for disability insurance benefits from the Social Security Administration in August 2012, citing limitations due to Wegener’s granulomatosis, depression, pulmonary disease, back injury, bipolar disorder, and excessive fatigue. She needed to establish disability between August 8, 2011, and December 31, 2016. Her application was initially denied in November 2012, followed by several unfavorable decisions from Administrative Law Judges (ALJs), appeals, and remands. The most recent ALJ decision concluded that she was not disabled during the relevant period, and the district court affirmed this decision.The United States District Court for the Eastern District of Wisconsin affirmed the ALJ’s decision, finding that substantial evidence supported the agency’s determination. The Appeals Council denied further review, making the ALJ’s decision the final decision of the Commissioner of Social Security.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The court held that the ALJ properly weighed the medical opinion evidence, including the opinions of Ms. Pufahl’s neurologist, primary care provider, and psychiatrist, and found substantial evidence supporting the ALJ’s decision to not give controlling weight to these opinions. The ALJ’s evaluation of Ms. Pufahl’s subjective complaints was not patently wrong, as it was supported by specific reasons and evidence. Additionally, the hypothetical question posed to the vocational expert (VE) sufficiently accounted for Ms. Pufahl’s mental limitations, including her ability to maintain attention and concentration for two-hour segments. The court concluded that the ALJ’s decision was supported by substantial evidence and affirmed the district court’s judgment. View "Pufahl v Bisignano" on Justia Law

Joe Feazell, an inmate at Pontiac Correctional Center, sued his doctor, Andrew Tilden, and the prison’s healthcare contractor, Wexford Health Sources, Inc., alleging deliberate indifference to his hemorrhoid condition and significant gastrointestinal bleeding, violating the Eighth Amendment. Feazell claimed that Dr. Tilden failed to respond promptly to his abnormal lab results and adequately treat his hemorrhoids, while Wexford's treatment protocol was ineffective and deliberately indifferent.The United States District Court for the Central District of Illinois initially denied the defendants' motion for summary judgment. The parties consented to proceed before a magistrate judge, who later granted summary judgment for Wexford and partial summary judgment for Dr. Tilden. Feazell went to trial on his remaining claim against Dr. Tilden but was barred from testifying about his medical diagnoses or their causes. The jury returned a verdict for the defense.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the magistrate judge's summary judgment decision, finding no evidence that Wexford's Collegial Review policy caused Feazell to receive deficient care or that Dr. Tilden was aware of Feazell's hemorrhoids before the colonoscopy. The court also upheld the magistrate judge's evidentiary rulings, barring Feazell from testifying about medical diagnoses or causation, as he was not qualified to provide such testimony.The Seventh Circuit concluded that Feazell failed to demonstrate a genuine issue of material fact regarding Wexford's policy causing a violation of his Eighth Amendment rights and that Dr. Tilden was not deliberately indifferent to Feazell's medical needs. The court affirmed the district court's judgment. View "Feazell v Wexford Health Sources, Inc." on Justia Law

Employees of United Airlines, including pilots, flight attendants, and other staff, challenged the company's COVID-19 vaccination mandate and masking requirement issued in 2021. United required employees to either get vaccinated or apply for religious or medical exemptions by specific deadlines. Plaintiffs alleged that despite submitting or attempting to submit exemption requests, they were either fired, placed on unpaid leave, or subjected to a hostile work environment.The United States District Court for the Northern District of Illinois dismissed the plaintiffs' claims with prejudice, finding that they had not stated any viable claim for relief despite having sufficient opportunities to do so. The court addressed each of the plaintiffs' twelve claims, noting that many were forfeited due to the plaintiffs' failure to respond to substantive arguments. The court also found deficiencies in the proposed amended complaints and ultimately dismissed the action with prejudice after determining that further amendments would be futile.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims were either improperly preserved or inadequately pled. The court found that the plaintiffs had forfeited their FDCA, invasion of privacy, and negligence claims by failing to address the district court's findings of forfeiture. The court also upheld the dismissal of the Illinois Whistleblower Act claim, as the plaintiffs did not show how receiving a COVID-19 vaccine would violate federal regulations. Additionally, the court affirmed the dismissal of the Title VII claims due to the plaintiffs' failure to obtain right-to-sue letters from the EEOC, which is a prerequisite for such lawsuits. The appellate court concluded that the district court did not err in denying further opportunities to amend the complaint. View "Anderson v. United Airlines" on Justia Law

Dr. William Partin filed a lawsuit against Baptist Healthcare System, Inc. and Dr. Daniel Eichenberger after he resigned from his position. Partin alleged that Baptist and Eichenberger retaliated against him in violation of the Emergency Medical Treatment and Active Labor Act (EMTALA) and brought claims under Indiana law for breach of contract, tortious interference with contractual relations, and defamation. The dispute arose from Partin's treatment of a suicidal patient, J.C., in Baptist's emergency department, where Partin ordered procedures against J.C.'s will, leading to complaints from hospital staff.The United States District Court for the Southern District of Indiana granted summary judgment in favor of Baptist and Eichenberger. The court found that no reasonable jury could conclude that Partin engaged in EMTALA-protected activity or that he was retaliated against for such activity. The court also determined that Partin's breach of contract claim failed because the bylaws did not create a contractual relationship between Partin and Baptist, and his resignation was not under duress. Additionally, the court found no evidence to support Partin's claims of tortious interference with contract or defamation.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Partin did not engage in EMTALA-protected activity and that his belief in reporting a potential EMTALA violation was not objectively reasonable. The court also agreed that the bylaws did not create a contract between Partin and Baptist and that Partin's resignation was voluntary. Furthermore, the court found that Baptist's actions were justified and not malicious, and that the statements made by Eichenberger and Marksbury were protected by qualified privilege and not made in bad faith. View "Partin v Baptist Healthcare System, Inc." on Justia Law

Mark Sorensen, owner of SyMed Inc., a Medicare-registered distributor of durable medical equipment, was involved in a business arrangement with PakMed LLC, Byte Success Marketing, and Dynamic Medical Management. They advertised orthopedic braces, obtained signed prescriptions from patients' doctors, distributed the braces, and collected Medicare reimbursements. Byte and KPN, another marketing firm, advertised the braces, and interested patients provided their information, which was forwarded to call centers. Sales agents then contacted patients, generated prescription forms, and faxed them to physicians for approval. Physicians retained discretion to sign and return the forms, with many choosing not to.A federal grand jury indicted Sorensen on four counts: one count of conspiracy and three counts of offering and paying kickbacks for Medicare referrals. The jury found Sorensen guilty on all counts. Sorensen moved for acquittal, arguing insufficient evidence and lack of awareness of the scheme's illegality. The district court denied his motions, finding the evidence sufficient for the jury to conclude Sorensen knew the fee structure and purchase of doctors' orders were illegal. Sorensen was sentenced to 42 months in prison but was released on bond pending appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the district court's judgment due to insufficient evidence. The court found that Sorensen's payments to PakMed, KPN, and Byte were for advertising, manufacturing, and shipping services, not for patient referrals. The court emphasized that the Anti-Kickback Statute targets payments to individuals with influence over healthcare decisions, which was not the case here. The court concluded that Sorensen's actions did not violate the statute, as there was no evidence of improper influence over physicians' independent medical judgment. View "USA v Sorensen" on Justia Law

Griffith Foods International and Sterigenics U.S. operated a medical supply sterilization plant in Willowbrook, Illinois, emitting ethylene oxide (EtO) over a 35-year period. In 2018, a report revealed high cancer rates in Willowbrook, allegedly due to these emissions. Griffith and Sterigenics faced over 800 lawsuits from residents claiming bodily injuries, including cancer, caused by the emissions. Griffith had obtained permits from the Illinois Environmental Protection Agency (IEPA) for the plant's operation, which included EtO emissions.The United States District Court for the Northern District of Illinois reviewed the case. Griffith and Sterigenics sought declarations that National Union Fire Insurance Company had a duty to defend them under their commercial general liability (CGL) policies. The district court ruled in favor of Griffith and Sterigenics, determining that the pollution exclusion in the CGL policies did not apply because the emissions were authorized by IEPA permits. The court relied on the Illinois appellate decision in Erie Insurance Exchange v. Imperial Marble Corp., which found ambiguity in the pollution exclusion when emissions were permitted by regulatory authorities.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court acknowledged the importance of the pollution exclusion in CGL policies and the precedent set by the Illinois Supreme Court in American States Insurance Co. v. Koloms. The Seventh Circuit noted the conflicting interpretations between Koloms and Imperial Marble regarding the scope of the pollution exclusion. Given the significant implications for Illinois law and the insurance industry, the Seventh Circuit decided to certify the question to the Illinois Supreme Court to determine the relevance of regulatory permits in applying the pollution exclusion in CGL policies. View "Griffith Foods International Inc. v National Union Fire Insurance Company of Pittsburg" on Justia Law

Rhonda Sutton was charged with conspiracy to commit health care fraud. At her arraignment in June 2018, the district court appointed counsel to represent her. Sutton pleaded not guilty in January 2020. After several delays due to the COVID-19 pandemic, the district court set her trial for November 2022. In September 2022, Sutton requested her attorneys to engage in plea negotiations, but she ultimately decided to proceed to trial. She then expressed dissatisfaction with her counsel and requested new representation. Her counsel filed a motion to withdraw, which the district court denied, citing no conflict or communication breakdown and suspecting a delay tactic.The United States District Court for the Northern District of Illinois denied Sutton's motion to substitute appointed counsel, finding no conflict or communication breakdown and suspecting her request was a delay tactic. The trial proceeded as scheduled, and the jury returned guilty verdicts on all counts. Post-trial, Sutton's counsel filed another motion to withdraw, which the district court granted, appointing new counsel for sentencing. At sentencing, Sutton raised objections to the proposed conditions of supervised release, but she waived her challenge to one condition by not objecting at the appropriate time.The United States Court of Appeals for the Seventh Circuit reviewed the case. Sutton raised two issues on appeal: the denial of her pretrial motion to withdraw and the constitutionality of a supervised release condition. The court held that the district court did not abuse its discretion in denying the motion to withdraw, as Sutton had no right to insist on counsel she could not afford, and her request appeared to be a delay tactic. The court also found that Sutton waived her challenge to the supervised release condition by not objecting at the appropriate time. The judgment of the district court was affirmed. View "USA v Sutton" on Justia Law

Indiana’s 2015 Vapor Pens and E-Liquid Act regulates the manufacture and distribution of vapor pens and the liquids used in e-cigarettes, Ind. Code 7.1-7- 1-1. The Act has extraterritorial reach and imposed detailed requirements of Indiana law on out-of-state manufacturing operations. It purported to regulate the design and operation of out-of-state production facilities, including requirements for sinks, cleaning products, and even the details of contracts with outside security firms and the qualifications of those firms’ personnel. The Seventh Circuit reversed dismissal of a challenge to the Act. Imposing these Indiana laws on out-of-state manufacturers violates the dormant Commerce Clause. Indiana has ample authority to regulate in-state commerce in vapor pens, e-liquids, and e-cigarettes to protect the health and safety of its residents, by prohibiting sales to minors and requiring child-proof packaging, ingredient labeling, and purity. The requirements for in-state production facilities pose no inherent constitutional problems. Indiana may not, however, try to achieve its health and safety goals by directly regulating out-of-state factories and commercial transactions. View "Legato Vapors, LLC v. Cook" on Justia Law

Flambeau adopted an employee wellness program, requiring its employees, as a condition of receiving employer-subsidized health insurance, to fill out a medical questionnaire and to undergo biometric testing. One employee did not meet those requirements in time for the 2012 benefit year;, he and his family were briefly without health insurance. He filed a complaint with the Equal Employment Opportunity Commission, which filed suit, arguing that Flambeau’s requirement violated the Americans with Disabilities Act (ADA) ban on involuntary medical examinations, 42 U.S.C. 12112(d)(4). The district court dismissed; the Seventh Circuit affirmed. The court declined to address whether wellness programs are exempt from the limits on medical examinations because the ADA does not “restrict … [an] organization … administering the terms of a bona fide benefit plan that are based on underwriting risks, classifying risks, or administering such risks that are based on or not inconsistent with State law” or the EEOC argument that this insurance safe harbor does not apply to wellness programs. The court held that the relief the EEOC sought is either unavailable or moot. The employee resigned before suit was filed. He did not incur damages as a result of Flambeau’s policy and is not entitled to punitive damages. Flambeau abandoned its wellness program requirements for reasons unrelated to the litigation. View "Equal Employment Opportunity Commission v. Flambeau, Inc." on Justia Law

Advocate Health Care and NorthShore University HealthSystem operate hospital networks in Chicago’s northern suburbs. They propose to merge. The Clayton Act forbids asset acquisitions that may lessen competition in any “section of the country,” 15 U.S.C. 18. The Federal Trade Commission and the state sought an injunction, pending the Commission’s consideration of the issue. To identify a relevant geographic market where anticompetitive effects of the merger would be felt, plaintiffs relied on the “hypothetical monopolist test,” which asks what would happen if a single firm became the sole seller in a proposed region. If such a firm could profitably raise prices above competitive levels, that region is a relevant geographic market. The Commission’s expert economist chose an 11-hospital candidate region and determined that it passed the hypothetical monopolist test. The district court denied a preliminary injunction, finding that the plaintiffs had not demonstrated a likelihood of success on the merits, but stayed the merger pending appeal. The Seventh Circuit reversed; the geographic market finding was clearly erroneous. The evidence was not equivocal: most patients prefer to receive hospital care close to home and insurers cannot market healthcare plans to employers with employees in Chicago’s northern suburbs without including some of the merging hospitals in their networks. The district court rejected that evidence because of some patients’ willingness to travel for care; its analysis erred by overlooking the market power created by the remaining patients’ preferences (the “silent majority” fallacy). View "FTC v. Advocate Health Care Network" on Justia Law