Justia Health Law Opinion Summaries

The case involves a group of plaintiffs, including the Health Freedom Defense Fund, Inc. and California Educators for Medical Freedom, who challenged the COVID-19 vaccination policy of the Los Angeles Unified School District (LAUSD). The policy, which was in effect for over two years, required employees to get the COVID-19 vaccination or lose their jobs. The plaintiffs argued that the policy interfered with their fundamental right to refuse medical treatment.The case was initially dismissed by the United States District Court for the Central District of California, which applied a rational basis review under Jacobson v. Massachusetts, concluding that the policy served a legitimate government purpose. The court held that even if the vaccine did not prevent transmission or contraction of COVID-19, it furthered the purpose of protecting LAUSD students and employees from COVID-19.The plaintiffs appealed to the United States Court of Appeals for the Ninth Circuit. During the appeal, LAUSD rescinded its vaccination policy. LAUSD then asked the court to dismiss the appeal, arguing that the case was now moot. The plaintiffs objected, arguing that LAUSD withdrew the policy because they feared an adverse ruling.The Ninth Circuit held that the case was not moot, applying the voluntary cessation exception to mootness. The court found that LAUSD's pattern of withdrawing and then reinstating its vaccination policies, particularly in response to litigation risk, was enough to keep the case alive.On the merits, the Ninth Circuit held that the district court misapplied the Supreme Court’s decision in Jacobson v. Massachusetts. The court found that Jacobson did not apply because the plaintiffs had plausibly alleged that the COVID-19 vaccine does not effectively prevent the spread of COVID-19. The court vacated the district court’s order and remanded the case for further proceedings under the correct legal standard. View "HEALTH FREEDOM DEFENSE FUND, INC. V. ALBERTO CARVALHO" on Justia Law

The case involves two petitioners, Daniel Dilly, Superintendent of the Rubenstein Juvenile Center (RJC), and Nancy Oldaker, Health Services Administrator at RJC, who were held in contempt of court by Judge Kurt Hall of the Circuit Court of Lewis County, West Virginia. The contempt charges arose from an incident involving a resident of RJC, identified as D.P., who suffered a broken jaw during a fight with other residents. The court had ordered that D.P. be taken off RJC grounds for an X-ray and that his mother be notified of his medical appointments. The court found that these orders were not adequately followed by the petitioners.The Circuit Court of Lewis County held a hearing to review D.P.'s placement and medical care, resulting in a "Medical Care Order" that directed RJC to schedule an appointment for D.P. with his oral surgeon and to allow D.P.'s mother to attend the appointment. The court also ordered RJC to provide a report concerning the incident that led to D.P.'s injury. When these orders were not fully complied with, the court held a "show cause" hearing and found both Superintendent Dilly and Ms. Oldaker in contempt of court, fining each of them $250.The Supreme Court of Appeals of West Virginia found that procedural errors in the lower court's contempt proceedings deprived the court of jurisdiction to impose such sanctions. The court noted that the lower court failed to provide the petitioners with adequate notice that they were facing indirect criminal contempt proceedings and did not afford them jury trials before imposing the fines. The court concluded that the contempt orders were void and granted the petitioners' requested writs of prohibition, thereby preventing the lower court from enforcing the contempt orders. View "State ex rel. Dilly v. Hall" on Justia Law

Barbara Harrison, a severely disabled individual, challenged the Texas Health and Human Services Commission's (HHSC) decision to deny funding for medical services she claimed were necessary for her survival. Harrison lived in a group home and received nursing services funded by HHSC’s program for providing home and community-based care to people with disabilities. However, when her condition deteriorated to the point where she required 24/7 one-on-one nursing care, HHSC determined that the cost of providing Harrison’s necessary level of care exceeded the cost cap set by the program. Harrison was therefore denied program-funded nursing services, meaning her only option for receiving government-funded medical care was to move to an institutional setting.Harrison challenged HHSC’s determination in court, arguing that HHSC discriminated against her because of her disability, in violation of the Americans with Disabilities Act (ADA) and the Rehabilitation Act, by denying her program-funded nursing services. The district court granted a preliminary injunction requiring HHSC to fund 24/7 one-on-one care for Harrison until she received a hearing on her request for general revenue funds. However, the United States Court of Appeals for the Fifth Circuit vacated the preliminary injunction and remanded for further proceedings, holding that Harrison was unlikely to succeed on her due process claim and had not demonstrated a likelihood of success on the ADA/Rehabilitation Act claims.After the case was remanded to the district court, Harrison submitted a new application to HHSC for 24-hour nursing care under the Program, the cost of which again exceeded the Cost Cap. HHSC determined that Harrison did not require 24-hour nursing care and that 5.5 hours of nursing care per day would be sufficient to meet her medical needs. The district court found that Harrison’s change in status— from receiving no Program funding to receiving some Program funding— mooted Harrison’s ADA/Rehabilitation Act claims. The court therefore dismissed them and then granted summary judgment to HHSC on Harrison’s due process claim. Harrison appealed this decision.The Fifth Circuit Court of Appeals affirmed the district court’s grant of summary judgment to HHSC on Harrison’s due process claim but reversed the district court’s dismissal of Harrison’s discrimination claims. The court found that the district court’s mootness determination was erroneous and that the factual record was still not sufficiently developed to support a judgment as to Harrison’s discrimination claims. The case was remanded for further factfinding and proceedings. View "Harrison v. Young" 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

The case involves Disability Rights Texas (DRTx), an advocacy organization for individuals with mental illness, and Houston Behavioral Healthcare Hospital (Houston Behavioral). DRTx sought to compel Houston Behavioral to disclose video footage related to the involuntary confinement of its client, G.S., who alleged abuse during his detention at the hospital. G.S. had signed a waiver allowing DRTx to access his records. Houston Behavioral initially cooperated with DRTx's requests for information but refused to provide the requested video footage, citing confidentiality regulations related to substance use disorder treatment.The United States District Court for the Southern District of Texas granted summary judgment in favor of DRTx and issued an injunction, compelling Houston Behavioral to disclose the video footage. Houston Behavioral appealed this decision.The United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The court found that the Protection and Advocacy for Individuals with Mental Illness Act (PAIMI Act) grants broad investigatory powers to organizations like DRTx, including access to "all records of any individual." The court held that the video footage requested by DRTx falls within the definition of "records" under the PAIMI Act. The court also found that the Health Insurance Portability and Accountability Act (HIPAA) does not bar the disclosure of such records, as the required-by-law exception in HIPAA permits disclosure when another law, such as the PAIMI Act, requires it. The court concluded that Houston Behavioral's refusal to provide the video footage violated the PAIMI Act. View "Disability Rights Texas v. Hollis" on Justia Law

In this case, Amy Bricker, a high-ranking executive, moved from Cigna Corporation to CVS Pharmacy, Inc., both of which are major healthcare conglomerates. Cigna sued Bricker and CVS, seeking to enforce a non-compete agreement that Bricker had signed while employed at Cigna. The district court granted a temporary restraining order and a preliminary injunction to preserve the status quo and protect Cigna's business interests. Bricker and CVS appealed the preliminary injunction.Previously, the district court had found that Cigna's protected interests were numerous and substantial, spanning multiple lines of products and services. It also found that Bricker likely retained a considerable amount of protected information from her time at Cigna. The court concluded that Cigna had a fair chance of demonstrating that the non-compete agreement was reasonable and enforceable under Missouri law.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court agreed with the lower court's findings and concluded that the non-compete agreement was likely enforceable under Missouri law. The court also found that Cigna would likely suffer irreparable harm if the preliminary injunction was not granted, as Bricker could potentially disclose Cigna's trade secrets to CVS. The court concluded that the balance of equities favored Cigna and that the public interest supported the enforcement of contractual obligations. Therefore, the court held that the district court did not abuse its discretion in granting the preliminary injunction. View "Cigna Corporation v. Bricker" on Justia Law

A class of individuals and businesses in Northern California, who paid health insurance premiums to certain health plans, sued Sutter Health, a healthcare system operator in the region. They alleged that Sutter abused its market power to charge supracompetitive rates to these health plans, which were then passed on to the class in the form of higher premiums. The case went to trial on claims under California’s Cartwright Act for tying and unreasonable course of conduct. The jury returned a verdict in favor of Sutter.The plaintiffs appealed, arguing that the district court erred by failing to instruct the jury to consider Sutter’s anticompetitive purpose and by excluding evidence of Sutter’s conduct before 2006. The United States Court of Appeals for the Ninth Circuit agreed with the plaintiffs. It held that the district court contravened California law by removing “purpose” from the jury instructions, and that the legal error was not harmless. The court also held that the district court abused its discretion under Federal Rule of Evidence 403 in excluding as minimally relevant all evidence of Sutter’s conduct before 2006. The court concluded that these errors were prejudicial and reversed the district court’s judgment, remanding the case for a new trial. View "SIDIBE V. SUTTER HEALTH" on Justia Law

Mohamed Gamar Ahmed was charged with possession of cocaine and fentanyl with intent to distribute, and possession of a firearm in furtherance of a drug trafficking crime. The charges stemmed from a search warrant executed at Ahmed's residence in Nebraska, where law enforcement officers discovered loaded handguns, ammunition, drug paraphernalia, marijuana, cocaine, and counterfeit Percocet pills containing fentanyl. Ahmed pleaded guilty to the charges. The United States Probation Office prepared a presentence investigation report (PSR), which alleged that Ahmed had supplied one of the fentanyl-laced pills to a minor female, who overdosed after ingesting it. The Government filed a motion for an upward departure or variance on the drug-possession count, arguing that the United States Sentencing Guidelines range of 15-21 months’ imprisonment failed to adequately account for the extent of the harm caused by Ahmed’s drug-dealing.The District Court for the District of Nebraska conducted an evidentiary hearing at sentencing that involved testimony from two witnesses. After hearing the direct- and cross-examinations of both witnesses, the district court overruled Ahmed’s objection to the PSR, finding that the testimony was consistent with the allegation that Ahmed supplied the pill that caused the minor to overdose. The district court then proceeded to sentencing, stating that it had considered all the federal sentencing factors enumerated in 18 U.S.C. § 3553(a), including the serious nature of the offense and Ahmed’s history and characteristics. The district court varied upward on the drug-possession count to reflect the seriousness of the offense, to promote respect for the law, and to provide just punishment, ultimately sentencing Ahmed to 48 months’ imprisonment. Ahmed also received a mandatory minimum term of 60 months’ imprisonment on the firearm-possession count, to be served consecutively, for a total of 108 months’ imprisonment.Ahmed appealed to the United States Court of Appeals for the Eighth Circuit, alleging that the district court committed procedural error and imposed a substantively unreasonable sentence. The appellate court affirmed the district court's decision, finding no procedural error and concluding that the district court imposed a substantively reasonable sentence. View "United States v. Ahmed" on Justia Law

A Rhode Island oral and maxillofacial surgeon, Dr. Stephen T. Skoly, refused to comply with a COVID-19 Emergency Regulation issued by the Rhode Island Department of Health (RI DOH) that required all healthcare workers and providers to be vaccinated against COVID-19. Following his public declaration of noncompliance, the RI DOH issued a Notice of Violation and Compliance Order against him. Skoly then filed a lawsuit in federal court against the state and its officials, alleging violations of equal protection, due process, and First Amendment rights. The district court dismissed his complaint under Federal Rule of Civil Procedure 12(b)(6).The district court's decision was based on the fact that the state officials were either entitled to absolute or qualified immunity for their actions. The court held that the RI DOH directors were exercising prosecutorial authority delegated to them by Rhode Island law, thus granting them absolute immunity. As for Governor McKee, the court found that he was protected by qualified immunity as Skoly had no clearly established right to continue practicing while violating the vaccine mandate. The court also rejected Skoly's First Amendment retaliation claim, stating that the posting of the Notice constituted government speech, which could not form the basis of a plausible First Amendment retaliation claim.Upon appeal, the United States Court of Appeals for the First Circuit affirmed the district court's dismissal of Skoly's complaint. The appellate court agreed with the lower court's findings that the state officials were entitled to either absolute or qualified immunity and that Skoly's constitutional claims were without merit. The court also upheld the dismissal of Skoly's First Amendment retaliation claim, stating that Skoly had not sufficiently alleged that he was targeted due to his opposition to the First Emergency Regulation. View "Skoly v. McKee" on Justia Law

The case revolves around Morgan Morales, who appealed against an administrative law judge's (ALJ) decision that she was not disabled and hence, not entitled to Social Security disability benefits. Morales claimed to suffer from several conditions, including bipolar disorder, depression, anxiety, ADHD, and narcolepsy. After being treated at a mental health center and starting on prescription medications, Morales reported that her conditions were in remission. The ALJ, however, denied her application for benefits, finding that her mental impairments were mild and did not limit her ability to perform basic work activities, including her past job as a material handler.Morales challenged the ALJ's decision in the United States District Court for the Southern District of Indiana, Indianapolis Division. She criticized the ALJ's decision about her functional capacity to work but failed to provide evidence compelling the conclusion that the adverse disability decision lacked substantial support in the record. The District Court upheld the ALJ's decision, stating that Morales had not carried her burden of proof and that the ALJ's decision was supported by substantial evidence.The case was then brought to the United States Court of Appeals for the Seventh Circuit. The court affirmed the lower court's decision, stating that Morales had misunderstood the burden she bore on appeal. The court noted that it was not enough to criticize the ALJ's decision; Morales needed to point to evidence compelling the conclusion that the adverse disability decision lacked substantial support in the record. The court also dismissed Morales's criticism of the District Court's decision, stating that the District Court had conducted an adequate review of the ALJ's determination and correctly applied the law. The court concluded that the ALJ's determination was reasonable and supported by substantial evidence, and therefore, affirmed the decision. View "Morales v. O'Malley" on Justia Law