Justia Health Law Opinion Summaries

Annette McEachin, a human resources manager, was seriously injured in a car accident in 2017 and subsequently filed a disability claim with Reliance Standard Life Insurance Company. Reliance approved her for long-term disability benefits, which were later extended after another car accident worsened her condition. McEachin underwent multiple surgeries and treatments for her physical injuries and also received treatment for mental health issues, including depression and anxiety, exacerbated by her son's suicide in 2019. Reliance paid her benefits for nearly four years but stopped payments in April 2021, concluding that her physical health had improved sufficiently for her to return to work.The United States District Court for the Eastern District of Michigan found that McEachin no longer had a physical disability as of April 2021 but ruled that her mental health disabilities entitled her to two more years of benefits. Both parties appealed the decision. Reliance argued that the district court misinterpreted the insurance policy, while McEachin contended that her physical disabilities persisted beyond April 2021.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that McEachin's physical disabilities alone justified her disability benefits until April 2021, meaning the 24-month mental health limitation did not apply until then. The court affirmed the district court's finding that McEachin's physical disabilities no longer rendered her totally disabled as of April 2021. However, the court vacated the district court's decision regarding the mental health benefits and remanded the case to consider whether McEachin's post-April 2021 medical evidence could toll the 24-month mental health limitation period, potentially extending her eligibility for benefits beyond April 2023. View "McEachin v. Reliance Standard Life Ins. Co." on Justia Law

Chadrick Perry was indicted for being a felon in possession of a firearm and ammunition. After pleading not guilty, he was detained pending trial. Concerns about his competency led to evaluations by two forensic psychologists, who reached different conclusions. The district court committed Perry to the custody of the Attorney General for competency restoration. Perry experienced significant delays in being transported to a federal facility for treatment. Eventually, he was deemed competent, pleaded guilty to being a felon in possession of ammunition, and was sentenced to 57 months in prison.The United States District Court for the Western District of Michigan denied Perry's motion to dismiss the indictment based on alleged violations of the Speedy Trial Act. Perry argued that the 152-day delay between his designation for treatment and his arrival at the facility should count against the Act's 70-day clock. The district court ruled that the entire period from when Perry was deemed incompetent until his competency was restored was excludable under the Act.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the entire period of delay resulting from Perry's mental incompetence was excludable under 18 U.S.C. § 3161(h)(4). This exclusion applied even during the transportation delay, thus not violating the Speedy Trial Act. Additionally, the court upheld Perry's sentence, determining that his prior conviction for aggravated domestic violence qualified as a "crime of violence" under U.S.S.G. § 4B1.2(a), justifying the increased Guidelines range. The court affirmed both the conviction and the sentence. View "United States v. Perry" on Justia Law

In 2021, the U.S. Department of Health and Human Services (HHS) issued a rule requiring Title X grant recipients to provide neutral, nondirective counseling and referrals for abortions upon patient request. Tennessee, a long-time Title X recipient, recently enacted laws criminalizing most abortions. Consequently, Tennessee limited its counseling and referrals to options legal within the state, leading HHS to discontinue its Title X grant, citing non-compliance with federal regulations. Tennessee sued to challenge this decision and sought a preliminary injunction to prevent the grant's termination.The United States District Court for the Eastern District of Tennessee denied Tennessee's request for a preliminary injunction. The court concluded that Tennessee was unlikely to succeed on the merits of its claim and that the balance of the preliminary injunction factors favored HHS. The court found that Tennessee did not demonstrate a strong likelihood of success on its claims under the Spending Clause or the Administrative Procedure Act (APA).The United States Court of Appeals for the Sixth Circuit reviewed the district court's decision and affirmed the denial of the preliminary injunction. The appellate court held that HHS's 2021 Rule was a permissible construction of Title X and that Tennessee had voluntarily and knowingly accepted the grant's terms, including the counseling and referral requirements. The court also found that HHS's actions did not violate the Spending Clause or the APA. The court concluded that Tennessee failed to show irreparable harm and that the public interest favored the correct application of Title X regulations. Therefore, the district court's decision to deny the preliminary injunction was upheld. View "Tennessee v. Becerra" on Justia Law

The case involves Joseph Betro, Mohammed Zahoor, Tariq Omar, and Spilios Pappas, who conspired to defraud Medicare by administering medically unnecessary back injections and bribing patients with opioid prescriptions. They fraudulently billed these injections as “facet injections” to receive higher reimbursements. Additionally, they ordered unnecessary urine drug tests and referred patients to ancillary services in exchange for kickbacks. Despite patient complaints about the ineffectiveness and pain of the injections, the defendants continued their fraudulent practices.A jury in the United States District Court for the Eastern District of Michigan convicted the defendants of conspiracy to commit healthcare fraud and wire fraud under 18 U.S.C. § 1349 and healthcare fraud under 18 U.S.C. § 1347. The defendants filed motions for a new trial, which the district court denied. They then appealed their convictions and sentences, raising various challenges related to the prosecution, evidence admission, jury instructions, and sentencing calculations.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgments. The court found sufficient evidence to support the jury’s findings that the defendants knowingly participated in the fraudulent scheme. The court also held that the district court did not abuse its discretion in denying the motions for a new trial, admitting evidence, or instructing the jury. The sentences imposed were deemed procedurally and substantively reasonable, with the court noting that the district court had appropriately calculated the loss amounts and applied relevant sentencing enhancements. View "United States v. Betro" on Justia Law

The case involves the United States of America, et al. ex rel. Michael Angelo and MSP WB, LLC (Relators-Appellants) against Allstate Insurance Company, et al. (Defendants-Appellees). The relators alleged that Allstate Insurance violated the False Claims Act by avoiding its obligations under the Medicare Secondary Payer Act. They claimed that Allstate failed to report or inaccurately reported to the Centers for Medicare & Medicaid Services (CMS) information regarding its beneficiaries, which led to Allstate failing to reimburse Medicare for auto-accident-related medical costs incurred by beneficiaries insured by Allstate.The United States District Court for the Eastern District of Michigan dismissed the case with prejudice, deeming the relators' second amended complaint deficient in numerous respects. The relators then moved for reconsideration, which the district court denied. They also filed a motion to amend or correct under Rule 59(e), asking the district court to amend its judgment to dismiss the case without prejudice to allow them to file another amended complaint. The district court denied the motion on all grounds.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the relators failed to state a claim for a violation of the False Claims Act. The court noted that the relators did not provide sufficient facts demonstrating that Allstate had an "established duty" to pay money or property owed to the government. The court also found that the relators did not demonstrate Allstate's understanding that its conduct violated its obligations under federal law. Furthermore, the court found that the relators' claim for conspiracy also failed as they did not provide any specific details regarding the alleged plan or an agreement to execute the plan. The court also affirmed the district court's decision to deny the relators leave to amend their complaint again. View "United States ex rel. Angelo v. Allstate Insurance Co." on Justia Law

The case involves Dr. Peter Bolos, who was convicted of mail fraud, conspiracy to commit healthcare fraud, and felony misbranding as part of a complex scheme. Bolos purchased an interest in Florida-based pharmacy Synergy Pharmacy Services in 2013 and became the managing partner. Synergy signed an agreement with HealthRight, a telemarketing firm, to generate business. HealthRight used social media advertisements and large phone banks to generate potential clients for Synergy. The information collected from potential clients was forwarded to a licensed doctor in the patient’s home state for review. Most of these decisions were made without the doctor ever seeing or speaking to the patient. The doctors then sent the prescriptions to Synergy for filling.The District Court for the Eastern District of Tennessee convicted Bolos on all counts after a four-week trial. Bolos appealed, arguing that his actions were not unlawful and that he was being unfairly held criminally culpable for contractual violations and others’ misconduct.The United States Court of Appeals for the Sixth Circuit disagreed with Bolos and affirmed the lower court's decision. The court found that Bolos and Synergy leadership knew of the deficiencies in their business practices and either actively facilitated and furthered them or turned a blind eye, all in an effort to induce Pharmacy Benefit Managers (PBMs) to pay Synergy. The court also held that the federal healthcare-fraud statute requires the government to prove that Bolos knowingly devised a scheme or artifice to defraud a health care benefit program in connection with the delivery of or payment for health care benefits, items, or services. The court found ample evidence in the record to support the jury’s finding that Bolos conspired to create a scheme with the intent to defraud the PBMs of their money. View "United States v. Bolos" on Justia Law

The case involves Dr. John Stanton, who served as the medical director for a pain clinic in Tennessee. The federal government alleged that the clinic operated as a pill mill, and charged Dr. Stanton with conspiring to violate federal drug laws. Despite numerous red flags indicating the clinic's operation as a pill mill, Dr. Stanton continued to sign off on state compliance reports and prescribe narcotics to patients who failed drug screens. The government indicted Dr. Stanton, along with the clinic's owner and two patient sponsors, for conspiring to distribute controlled substances without a legitimate medical purpose.The case was first heard in the United States District Court for the Eastern District of Kentucky, where Dr. Stanton was found guilty by a jury. At sentencing, the court concluded that Dr. Stanton had prescribed a converted drug weight of at least 21,524 kilograms, leading to a recommended minimum sentence of 188 months. The trial court, however, varied downward to 120 months.Upon appeal to the United States Court of Appeals for the Sixth Circuit, Dr. Stanton challenged the sufficiency of the evidence supporting the jury’s verdict and several rulings by the trial court. The appellate court affirmed the lower court's decision. The court found that there was sufficient evidence to support the jury's finding that Dr. Stanton knowingly agreed to help the clinic and its owner illegally distribute controlled substances. The court also found no abuse of discretion in the trial court's decisions, including the allowance of a new expert witness for the government, the instruction to the jury on deliberate ignorance, and the response to the jury’s questions about the jury instructions. The court also upheld the drug weight calculation at sentencing. View "United States v. Stanton" on Justia Law

An inmate, Timothy Finley, who suffers from severe psychiatric disorders, was placed in a heavily restrictive cell in administrative segregation for approximately three months by prison officials. Finley brought a case against the deputy wardens, Erica Huss and Sarah Schroeder, alleging violations of the Eighth Amendment and his right to procedural due process, as well as disability-discrimination claims under the Americans with Disabilities Act and the Rehabilitation Act.The district court granted summary judgment to Huss and Schroeder on all claims. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the lower court's decision on Finley’s procedural due process and statutory discrimination claims. However, the court reversed the lower court's decision on Finley’s Eighth Amendment claim, finding that he presented sufficient evidence to find that the deputy wardens violated his clearly established rights. The court remanded the case for further proceedings on the Eighth Amendment claim. View "Finley v. Huss" on Justia Law

The case involves the family of Todd Kerchen, who died from a lethal dose of fentanyl. The family filed a complaint against the University of Michigan and Dr. James Woods, alleging violations under 42 U.S.C. § 1983 and Michigan state law. The family claimed that the fentanyl that killed Todd originated from a University of Michigan pharmacology lab where Christian Raphalides, the person who allegedly provided the drug to Todd, worked. The lab was overseen by Dr. Woods. The family argued that the lab's lax policies surrounding the use of controlled substances led to Todd's death.The district court denied the defendants' motion to dismiss and ordered limited discovery on whether the action was barred by the statutes of limitations applicable to the plaintiffs' claims. The defendants appealed this decision.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The court found that the University of Michigan and Dr. Woods in his official capacity were entitled to sovereign immunity, barring all claims against them. The court also found that Dr. Woods in his individual capacity was entitled to qualified immunity, barring the § 1983 claim against him. Furthermore, the court found that the wrongful death claim against Dr. Woods in his individual capacity should be dismissed as it was barred by governmental immunity. The court dismissed the remainder of the defendants' appeal for lack of jurisdiction. View "Kerchen v. University of Michigan" on Justia Law

The case involves Terrence Jordan and Damara Sanders, who were pulled over by a state trooper for speeding. During the stop, the trooper noticed inconsistencies in their travel plans and observed Jordan's heavy breathing, which raised his suspicion. He called for a canine unit, which detected the presence of drugs. A subsequent search of the vehicle and the defendants revealed marijuana, pill presses, digital scales, plastic baggies, firearms, and a significant quantity of pills containing a fluorofentanyl-fentanyl mixture.The defendants were charged with possessing a firearm as a felon, possessing a controlled substance with the intent to distribute, and possessing firearms in furtherance of drug trafficking. They sought to suppress the evidence obtained from the traffic stop, arguing that the trooper lacked reasonable suspicion to extend the stop. The District Judge denied the motion. The defendants also proposed a lesser-included-offense instruction for simple possession of a controlled substance, which the court rejected, citing the quantity of drugs and distribution paraphernalia as evidence of intent to distribute.The United States Court of Appeals for the Sixth Circuit affirmed in part, vacated in part, and remanded for further proceedings. The court held that the trooper had reasonable suspicion to extend the stop, based on the defendants' suspicious travel plans, Sanders's implausible explanations, and Jordan's heavy breathing. The court also agreed with the district court's decision not to give a lesser-included-offense instruction, given the substantial evidence of the defendants' intent to distribute drugs. However, the court vacated the defendants' convictions for possessing firearms in furtherance of drug trafficking due to an error in the jury instructions. The case was remanded for further proceedings consistent with the court's opinion. View "United States v. Jordan" on Justia Law