Justia Health Law Opinion Summaries

In this case where Plaintiffs sought a declaration that the Massachusetts Constitution protects a fundamental right to physician-assisted suicide, thereby immunizing the practice from criminal prosecution, the Supreme Judicial Court held that the proposed right, as defined by Plaintiffs, was not supported in the relevant provisions of the Constitution.Plaintiffs were a licensed physician who wished to provide physician-assisted suicide and a retired physician who had been diagnosed with an incurable cancer. Plaintiffs brought a civil action seeking declaratory and injunctive relief, arguing that terminally ill patients with six months or less to live have a constitutional right to receive a prescription for lethal medication in order to bring about death in a manner and time of their choosing. The trial court granted summary judgment for Defendants. The Supreme Judicial Court affirmed, holding (1) the Massachusetts Declaration of Rights does not protect physician-assisted suicide; and (2) the law of manslaughter prohibits physician-assisted suicide without offending constitutional protections. View "Kligler v. Attorney General" on Justia Law

DiMasi, then a 47-year-old nurse-practitioner student, received an influenza vaccine on December 4, 2012. She was admitted to the hospital on December 5, 2012, released the next day, and then readmitted on December 8. Almost three years later, DiMasi sought compensation under 42 U.S.C. 300aa-10 to -34 (Vaccine Act). In 2019, a special master denied compensation, noting that the parties agreed on the post-vaccination conditions at issue, ultimately diagnosed in 2016 and 2017: “small fiber neuropathy” and “postural tachycardia syndrome” (POTS), which are related. He also noted that no claim of significant aggravation of a preexisting condition had been presented and found that the vaccine was not the cause in fact of the conditions. DiMasi had 30 days to seek Claims Court review.On September 15, 2020, within a year of the final judgment, DiMasi sent the special master a letter, with medical records and other attachments, requesting that she be allowed to proceed pro se and that her case be reopened. The special master allowed DiMasi to proceed pro se and construed her request to reopen her case as a motion for relief from judgment under Claims Court Rule 60. The special master ultimately vacated the denial. The Federal Circuit appointed counsel for DiMasi and requested additional briefing, noting that it had “more questions than answers” about the findings and proceedings concerning DiMasi’s former counsel’s submissions and choices. View "DiMasi v. Secretary of Health & Human Services" on Justia Law

Yale New Haven Hospital (“YNHH”) receives federal funds under the Medicare Act. As part of the statutory formula for determining appropriate funding, the Medicare Act directs the Secretary of Health and Human Services (the “Secretary”) to “estimate” the “amount of uncompensated care” that each hospital will provide to indigent patients in a given federal fiscal year (“FFY”). Here, YNHH contended that the Secretary failed to conduct adequate notice-and-comment rulemaking before choosing to use only YNHH’s historical data – and not that of a hospital that had recently merged into YNHH – to estimate YNHH’s amount of uncompensated care for FFY 2014. The Secretary moved to dismiss for lack of subject-matter jurisdiction under 42 U.S.C Section 1395ww(r)(3), which prohibits “judicial review” of “[a]ny estimate of the Secretary.” The district court denied the Secretary’s motion, reasoning that section 1395ww(r)(3) applies only to substantive challenges to estimates, but not to procedural challenges like YNHH’s. The district court subsequently granted summary judgment in favor of YNHH.   The Secretary appealed, disputing (1) the district court’s ruling that it had jurisdiction to consider YNHH’s procedural challenge, and alternatively (2) the district court’s merits ruling that the Secretary’s estimate was procedurally unlawful.   The Second Circuit reversed the district court’s denial of the Secretary’s motion to dismiss YNHH’s procedural challenge for lack of subject-matter jurisdiction; vacated, for lack of subject-matter jurisdiction, the district court’s grant of summary judgment for YNHH on its procedural challenge; REMAND the case to the district court with instructions to dismiss the remainder of YNHH’s action for lack of subject-matter jurisdiction; and dismissed YNHH’s cross-appeal disputing the district court’s chosen remedy. View "Yale New Haven Hosp. v. Becerra" on Justia Law

The Supreme Court affirmed the order of the trial court, after a hearing, finding B.N. to be severely disabled and to be in need of extended custody, care, and treatment, holding that the trial court abused its discretion, but the error was harmless.B.N. requested to appear at her commitment hearing in person, but the trial court denied the request, stating, "we're proceeding remotely due to the COVID-19 pandemic." On appeal, B.N. argued that the trial court's denial of her request for in-person hearing violated Administrative Rule 14 and constitutional and statutory provisions. The Supreme Court affirmed, holding (1) the trial court did not make the requisite findings of good cause to conduct B.N.'s commitment hearing virtually; but (2) the trial court's error was harmless. View "In re Civil Commitment of B.N." on Justia Law

The Supreme Court affirmed the decision of the court of appeals that Respondent's due process rights were not violated in the proceedings which led to the trial court's conclusion that Respondent had a mental illness and was dangerous to himself, holding that there was no error.At the end of a hearing, the trial court concluded that Respondent had a mental illness and was a danger to himself and entering a thirty-day commitment order. At issue was whether the trial court, in the absence of counsel for the state, called witnesses and elicited testimony during the hearing. The Supreme Court affirmed, holding that the trial court did not violate Respondent's due process right to an impartial tribunal. View "In re J.R." on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the Industrial Commission denying the Department's motion to dismiss Plaintiffs' claims arising from certain regulatory actions taken by the North Carolina Department of Health and Human Services in response to deficiencies that Department employees had identified during inspections of Plaintiffs' facility, holding that the Commission erred in failing to dismiss Plaintiffs' claims.Plaintiffs, an adult care home and its owner, contested the Department's regulatory actions by initiating a contested case before the Office of Administrative Hearings. The parties settled. Thereafter, Plaintiffs filed a claim with the Commission pursuant to the North Carolina State Tort Claims Act, alleging negligence. The Department filed a motion to dismiss on the grounds that Plaintiffs' claims were barred by the doctrine of sovereign immunity. The Commission denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) Plaintiffs' claims were barred by sovereign immunity; and (2) Plaintiffs failed to assert a viable negligence claim against the Department. View "Cedarbrook Residential Center, Inc. v. N.C. Dep't of Health & Human Services" on Justia Law

The Supreme Court affirmed the decision of the court of appeals concluding that the proceedings below did not result in a due process violation but reversed the court of appeals' decision to affirm the order of the trial court to have Respondent involuntarily committed, holding that the record evidence and the trial court's findings did not support that determination.The State filed a petition to have Respondent involuntarily committed for additional inpatient treatment pursuant to N.C. Gen. Stat. 122C-261 et seq. The court of appeals affirmed. The Supreme Court reversed in part, holding (1) the court of appeals properly found that there was no due process violation in the proceedings below; but (2) the trial court's findings could not be deemed sufficient to support a determination that Respondent posed a danger to himself given its failure to find a reasonable probability of Respondent suffering serious physical debilitation within the near future without immediate, involuntary commitment. View "In re C.G." on Justia Law

The Supreme Court held that the trial court did not violate Defendant's due process rights by proceeding with Defendant's involuntary commitment hearing when Defendant was not represented by counsel and that the trial court's factual findings were sufficient to support its conclusion that Defendant was dangerous to herself.Specifically, the Supreme Court held (1) the trial court did not violate Defendant's due process rights; (2) Defendant preserved her right to challenge the trial court's incorporation of a non-testifying physician's exam report into its findings of fact, and the trial court committed harmless error by incorporating the report into its findings of fact; and (3) the court of appeals correctly held that the trial court made sufficient findings of fact based on the evidence presented by the testifying witness to support its involuntary commitment decision. View "In re R.S.H." on Justia Law

The North Carolina Insurance Guaranty Association (“Appellant”) to the Center for Medicare and Medicaid Services (“CMS”) sought an advisory opinion about whether Appellant is required to reimburse Medicare for certain medical bills that Medicare pays on behalf of insured individuals. CMS declined to issue the requested opinion. Dissatisfied with this response, Appellant filed this action against Alex M. Azar, II, in his official capacity as Secretary of the United States Department of Health and Human Services (“HHS”), HHS, and CMS (collectively, “Appellees”).   In this appeal, Appellant challenges the district court’s determination that Appellant lacked standing to bring this action because it failed to plausibly allege that it suffered an injury-in-fact. Additionally, Appellant challenges the district court’s conclusion that it did not possess jurisdiction over the action because Appellant failed to exhaust its administrative remedies.   The Fourth Circuit affirmed the dismissal of Appellant’s complaint. The court concluded that the district court properly determined that it did not have jurisdiction over this case because 42 U.S.C. Section 405(h) precludes federal question jurisdiction for claims against the United States or its agents if such claims arise under the Medicare Act. The court further wrote that the existence of the administrative appeal is fatal to Appellant’s claim that it is completely precluded from seeking review of its argument that it is not a primary plan through the administrative process. Additionally, the court agreed with the district court that the ordinary exceptions to the exhaustion requirement are inapplicable here, particularly in light of the Supreme Court’s guidance in Illinois Council. View "North Carolina Insurance Guaranty Association v. Xavier Becerra" on Justia Law

This consolidated matter arose from a class action for damages filed by Louisiana health care providers for alleged violations of the Preferred Provider Organizations (“PPO”) statute. La. R.S. 40:2201, et seq. The Louisiana Supreme Court granted writs to interpret the statute and to determine whether defendant, Stratacare, Inc. (“Stratacare”), was a “group purchaser” subject to penalties for violating the mandatory notice provision of the statute. After a review of the record and the law, the Supreme Court concluded that Stratacare was not a group purchaser as contemplated by the statute. Therefore, the Court reversed the court of appeal, vacated the lower court judgments, and dismissed the case. View "Williams, et al. v. Bestcomp, Inc. et al." on Justia Law