Justia Health Law Opinion Summaries

Caris MPI, Inc. (Caris) provided cancer diagnostic services to UnitedHealthcare, Inc. (United) for over ten years without a written contract. United audited Caris’s past claims and determined that Caris had used incorrect billing codes, resulting in overpayments. United began recouping these overpayments by offsetting them against new payment claims from Caris. Caris challenged United’s recoupment through United’s internal process, but after United rejected Caris’s appeals, Caris filed suit in Texas state court alleging various state law claims.United removed the case to the United States District Court for the Northern District of Texas, asserting federal officer jurisdiction under 28 U.S.C. § 1442(a)(1). The district court denied Caris’s motion to remand and dismissed Caris’s claims without prejudice, finding that Caris failed to exhaust administrative remedies under the Medicare Act.The United States Court of Appeals for the Fifth Circuit reviewed the case and agreed that federal officer jurisdiction existed. However, the court found that the district court erred in dismissing Caris’s claims for failure to exhaust administrative remedies. The Fifth Circuit held that the administrative review process under Medicare Part C does not extend to claims where an enrollee has no interest, and there were no administrative remedies for Caris to exhaust. The court distinguished this case from others by noting that no enrollee had requested an organization determination or appeal, and all enrollees had already received the services for which United sought recoupment. Consequently, the court affirmed the denial of the remand motion, reversed the dismissal of Caris’s claims, and remanded the case for further proceedings. View "Caris MPI v. UnitedHealthcare, Incorporated" on Justia Law

Hector Rodriguez-Pena was convicted in 1993 for his involvement in a drug trafficking conspiracy, firearms possession, and the attempted murder of federal law enforcement officers. He was sentenced to a total of 622 months' imprisonment, which was later reduced to 570 months. Over the years, Rodriguez-Pena has repeatedly challenged his sentence and conviction through various legal avenues, including direct appeals and motions for sentence modifications, all of which were denied.Rodriguez-Pena filed a motion for compassionate release in the U.S. District Court for the District of Puerto Rico, citing his vulnerability to COVID-19 due to his health conditions and the prevalence of the virus in his prison facility, FCI Coleman Low. He argued that his medical conditions, including high blood pressure and hyperlipidemia, increased his risk of severe complications from COVID-19. The district court denied his motion, concluding that he did not demonstrate extraordinary and compelling reasons for a sentence reduction, particularly noting his vaccination status and the low COVID-19 infection rates in his facility.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court found that the district court did not abuse its discretion in concluding that Rodriguez-Pena's risk from COVID-19, given his vaccination status and the conditions at FCI Coleman Low, did not constitute an extraordinary and compelling reason for compassionate release. The court also noted that the district court properly considered the evidence and arguments presented, including the effectiveness of COVID-19 vaccines and the current state of the pandemic within the prison. View "US v. Rodriguez-Pena" on Justia Law

The case involves a congressional program that awards grants for family-planning projects, with the Department of Health and Human Services (HHS) setting eligibility requirements. Oklahoma, a grant recipient, expressed concerns about these requirements, citing state laws prohibiting counseling and referrals for abortions. HHS proposed that Oklahoma provide neutral information about family-planning options, including abortion, through a national call-in number. Oklahoma rejected this proposal, leading HHS to terminate the grant. Oklahoma challenged the termination and sought a preliminary injunction.The United States District Court for the Western District of Oklahoma denied Oklahoma's motion for a preliminary injunction, determining that Oklahoma was unlikely to succeed on the merits of its claims. Oklahoma then appealed the decision.The United States Court of Appeals for the Tenth Circuit reviewed the case. Oklahoma argued that it would likely succeed on the merits for three reasons: (1) Congress's spending power did not allow it to delegate eligibility requirements to HHS, (2) HHS's requirements violated the Weldon Amendment, and (3) HHS acted arbitrarily and capriciously. The Tenth Circuit rejected these arguments, holding that:1. The spending power allowed Congress to delegate eligibility requirements to HHS, and Title X was unambiguous in conditioning eligibility on satisfaction of HHS's requirements. 2. The Weldon Amendment, which prohibits discrimination against health-care entities for declining to provide referrals for abortions, was not violated because HHS's proposal to use a national call-in number did not constitute a referral for the purpose of an abortion. 3. HHS did not act arbitrarily and capriciously in terminating Oklahoma's grant, as the eligibility requirements fell within HHS's statutory authority, and Oklahoma did not demonstrate a likely violation of HHS's regulations.The Tenth Circuit affirmed the district court's denial of the preliminary injunction, concluding that Oklahoma had not shown a likelihood of success on the merits of its claims. View "State of Oklahoma v. HHS" on Justia Law

K.B., a patient at the Alaska Psychiatric Institute (API), has been under successive involuntary commitment orders since 2019 due to his diagnoses of schizoaffective disorder, antisocial personality disorder, and traumatic brain injury. His condition has led to violent outbursts and delusional behavior, resulting in his banishment from local shelters and hotels. In September 2022, Dr. Anthony Blanford, K.B.'s attending psychiatrist, filed another 180-day commitment petition. During the proceedings, K.B. expressed dissatisfaction with his appointed attorney, particularly over whether his trial would be by jury or bench.The Superior Court of the State of Alaska, Third Judicial District, Anchorage, initially set the trial for late September. K.B.'s attorney informed the court that K.B. had requested a jury trial. However, on the first day of jury selection, K.B. indicated he preferred a bench trial. The court allowed defense counsel to consult with K.B., who confirmed his preference for a bench trial. The next day, K.B.'s attorney reported that K.B. had fired him for not listening and reiterated his preference for a bench trial. After further consultation, the attorney confirmed K.B.'s preference for a bench trial, and the court proceeded accordingly, ultimately granting the 180-day commitment petition.The Supreme Court of the State of Alaska reviewed the case. K.B. argued that the superior court erred by not conducting a representation hearing or inquiring further into his dissatisfaction with his attorney. The Supreme Court held that the superior court was not required to delve further into the attorney-client relationship. The court found that the circumstances, viewed objectively, did not indicate a breakdown in communication or decision-making capability between K.B. and his attorney. Therefore, the superior court's order granting the 180-day commitment was affirmed. View "In re Hospitalization of K.B." on Justia Law

Law enforcement executed a search warrant at Ryan Dewayne Myrick’s apartment, discovering 69.01 grams of methamphetamine, drug packaging, a digital scale, and other paraphernalia. In his vehicle, they found additional drug packaging. Myrick was charged with conspiracy to distribute methamphetamine and possession with intent to distribute. He pleaded guilty to the latter charge, admitting to possessing 69.01 grams of methamphetamine, with the intent to distribute at least 50 grams. The government agreed to dismiss the conspiracy charge and recommend a reduction for acceptance of responsibility, contingent on Myrick’s continued demonstration of acceptance.The United States District Court for the Southern District of Iowa reviewed the case. The Presentence Investigation Report (PSR) recommended holding Myrick responsible for 4.5 kilograms or more of methamphetamine, resulting in a base offense level of 38. It also suggested a two-level enhancement for maintaining a premises for drug distribution and a three-level reduction for acceptance of responsibility. Myrick objected to the drug quantity and the premises enhancement, while the government objected to the reduction for acceptance of responsibility. The district court overruled Myrick’s objections and sustained the government’s, resulting in a total offense level of 40 and an advisory Guidelines range of 360 months to life. Myrick was sentenced to 300 months of imprisonment and 5 years of supervised release.The United States Court of Appeals for the Eighth Circuit reviewed the case. Myrick challenged the district court’s drug quantity determination, the premises enhancement, and the denial of a reduction for acceptance of responsibility. The appellate court found no clear error in the district court’s findings, including the credibility of witness testimony and the application of relevant conduct principles. The court affirmed the district court’s judgment, upholding Myrick’s sentence. View "United States v. Myrick" on Justia Law

Three sets of parents refused to allow their newborns to receive Vitamin K shots at private hospitals in Illinois due to concerns about risks and religious reasons. Hospital staff reported the refusals to the Illinois Department of Children and Family Services (DCFS), which investigated the parents for medical neglect. In one case, hospital staff took temporary protective custody of the child. The parents sued under 42 U.S.C. § 1983, alleging violations of their Fourth and Fourteenth Amendment rights by the hospitals and medical professionals.The United States District Court for the Northern District of Illinois dismissed the cases, ruling that the private entities were not engaged in state action and thus not liable under § 1983. The parents appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the private hospitals and their staff did not act under color of state law. The court found no evidence of a conspiracy or joint action between the hospitals and DCFS to infringe on the parents' constitutional rights. The court also determined that the hospitals were not performing a public function traditionally reserved to the state, as the mere threat of taking protective custody did not constitute state action. Additionally, the court found no symbiotic relationship or entwinement between the hospitals and the state to the point of largely overlapping identity.The Seventh Circuit affirmed the district court's dismissal of the parents' claims, concluding that without state action, there could be no § 1983 liability. View "Bougher v. Silver Cross Hospital and Medical Centers" on Justia Law

This case involves a class action lawsuit against Logan Health Medical Center ("Logan Health") following a significant data breach of its information technology systems. The breach, which occurred on November 22, 2021, exposed highly sensitive personal identifying information and protected health information of over 200,000 current and former patients and others affiliated with Logan Health. Patricia Tafelski, on behalf of herself and all others similarly situated, filed a complaint against Logan Health. After a series of negotiations, the parties agreed to a settlement of $4.3 million for a common fund. The District Court granted preliminary approval of the proposed settlement on December 6, 2022.The District Court of the Eighth Judicial District, in and for the County of Cascade, granted final approval of the Settlement Agreement, awarded Class Counsel attorney fees, and denied the Objectors’ motion for discovery. The Objectors, Mark Johnson and Tammi Fisher, appealed the order, arguing that the attorney fees of 33.33% of the settlement fund were unreasonable and that their motion for discovery was wrongly denied.The Supreme Court of the State of Montana affirmed the lower court's decision. The court found that the District Court did not abuse its discretion in awarding Class Counsel attorney fees. The court also found that the District Court did not abuse its discretion in denying the Objectors’ motion for discovery. The court noted that the District Court had made adequate findings on each of the factors for determining the reasonableness of attorney fees and that those findings were supported by the record. The court also noted that the District Court had conscientiously considered the nature of the litigation and the interests of the class in denying the Objectors’ motion for discovery. View "Tafelski v. Johnson" on Justia Law

The case involves Jamie Christopher Henderson, who was convicted and sentenced following a jury trial for conspiracy to distribute cocaine and cocaine base, possession with intent to distribute cocaine base, and possession of firearms in furtherance of his drug trafficking crimes. Henderson appealed his convictions and sentence, arguing that the evidence was insufficient to support these convictions, and that his sentence is procedurally and substantively unreasonable.The case originated from an incident on April 30, 2019, when law enforcement officers executed a search warrant at Henderson’s residence. They witnessed Henderson toss items underneath a vehicle, including a gun. The officers recovered a loaded handgun, a plastic bag with cocaine and crack cocaine, a cigarette lighter, and a glass crack pipe from underneath the vehicle. Henderson was arrested. Inside the trailer, police found a loaded rifle, a loaded handgun, cocaine powder and crack cocaine in a toilet tank, and a second loaded handgun in a kitchen trash can. They also seized three digital scales and a digital video recorder containing footage from security cameras showing Henderson and other men, armed with multiple handguns and a rifle, standing in the front yard of the residence as cars and people would approach it.Henderson was charged with conspiracy to distribute cocaine and cocaine base, possession of a firearm in furtherance of the drug-distribution conspiracy, possession with intent to distribute cocaine and cocaine base, possession of a firearm in furtherance of the possession-with-intent offense, and possession of a firearm as a felon. He pleaded not guilty. At trial, the Government presented the testimony of the law enforcement officers, Henderson’s videotaped confession, the security footage from the trailer, and a letter Henderson had written to his brother. Henderson presented the testimony of his mother and daughter who claimed that Henderson was a drug user, thief, and liar—but not a drug dealer. The jury convicted Henderson on all counts.The United States Court of Appeals for the Fourth Circuit affirmed the convictions and sentence. The court found that there was substantial evidence to support the conviction and that the sentence was not procedurally or substantively unreasonable. The court noted that Henderson faced a heavy burden in challenging the sufficiency of the evidence and that the court's role was limited to considering whether there was substantial evidence to support the conviction. The court found that there was abundant independent evidence that Henderson was engaged in a large-scale drug trade, which supported the trustworthiness of his confessions. The court also found that the district court did not err in calculating the quantity of drugs attributable to Henderson for sentencing purposes. The court concluded that Henderson's sentence was substantively reasonable and that he failed to overcome the presumption of reasonableness that applies to a below-Guidelines sentence. View "United States v. Henderson" on Justia Law

The case involves three sets of plaintiffs who filed class-action lawsuits against their healthcare provider, Cedars-Sinai Health System and Cedars-Sinai Medical Center. The plaintiffs alleged that Cedars-Sinai unlawfully disclosed their private medical information to third parties through tracking software on its website. Cedars-Sinai removed the suits to federal court, arguing that it developed its website while acting under a federal officer and at the direction of the federal government.The district court disagreed with Cedars-Sinai's argument. It held that Cedars-Sinai developed its website in compliance with a generally applicable and comprehensive regulatory scheme and that there is therefore no federal jurisdiction under § 1442(a)(1). The court found that although Cedars-Sinai’s website furthers the government’s broad goal of promoting access to digital health records, Cedars-Sinai’s relationship with the federal government does not establish that it acted pursuant to congressionally delegated authority to help accomplish a basic governmental task.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s orders remanding the removed actions to state court. The court agreed with the district court that Cedars-Sinai developed its website in compliance with a generally applicable and comprehensive regulatory scheme under the Health Information Technology for Economic and Clinical Health Act, and that there was therefore no federal jurisdiction under § 1442(a)(1). The court concluded that Cedars-Sinai did not meet § 1442(a)(1)’s “causal nexus” requirement. View "Doe v. Cedars-Sinai Health System" on Justia Law

This case involves a qui tam action under the False Claims Act (FCA) and the Iowa False Claims Act (IFCA) brought by Stephen Grant, a sleep medicine practitioner, against Steven Zorn, Iowa Sleep Disorders Center, and Iowa CPAP. Grant alleged that the defendants had knowingly overbilled the government for initial and established patient visits and violated the Anti-Kickback Statute and the Stark Law by knowingly soliciting and directing referrals from Iowa Sleep to Iowa CPAP. The district court found the defendants liable for submitting 1,050 false claims to the United States and the State of Iowa and imposed a total award of $7,598,991.50.The district court had rejected the defendants' public disclosure defense and awarded summary judgment to the defendants on the Anti-Kickback Statute and Stark Law claim. After a bench trial, the district court found the defendants liable on several claims, including that Iowa Sleep had violated the anti-retaliation provisions of the FCA and IFCA by firing Grant. The district court also concluded that the defendants had overbilled on initial patient visits but not on established patient visits.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed in part, vacated in part, and remanded for further proceedings. The court held that the public disclosure bar was inapplicable because Grant’s complaint did not allege “substantially the same allegations” contained in the AdvanceMed letters. The court also held that the district court did not abuse its discretion in admitting expert testimony on extrapolation and overbilling. However, the court found that the district court erred in its determination of damages and civil penalties, violating the Eighth Amendment’s Excessive Fines Clause. The court vacated the punitive sanction and remanded the case for further proceedings. View "Grant v. Zorn" on Justia Law