Justia Health Law Opinion Summaries

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

The Supreme Court affirmed the order of the circuit court granting summary judgment in favor of Municipal Health Benefit Fund and dismissing this class action complaint challenging the Fund's decision to deny payment for portions of Plaintiff's daughter's medical bills based on its interpretation of the uniform, customary, and reasonable charges (UCR) exclusion in the Fund's policy booklet, holding that there was no error.Through his employment with a municipal police department, Plaintiff obtained health benefits coverage through the Fund. After Plaintiff's daughter was injured in a car accident the Fund denied payment for portions of her medical bills based on its interpretation of the UCR exclusion. Plaintiff then brought this class action against the Fund challenging the enforcement of the UCR term. The circuit court granted class certification and later granted summary judgment in favor of the Fund. The Supreme Court affirmed, holding that the circuit court did not err in granting summary judgment in favor of the Fund. View "Hendrix v. Municipal Health Benefit Fund" on Justia Law

Cliff Provins appealed a district court judgment affirming an administrative law judge’s (“ALJ”) decision that affirmed a Workforce Safety and Insurance (“WSI”) order denying liability for his post-traumatic stress disorder (“PTSD”) and ending disability benefits in November 2019. After review, the North Dakota Supreme Court concluded the ALJ did not err in concluding Provins’s PTSD was not compensable, and a reasoning mind could reasonably conclude his physical injuries did not cause his PTSD. View "Provins v. WSI, et al." on Justia Law

The Air Force ordered over 500,000 service members to get COVID-19 vaccinations. About 10,000 members requested religious exemptions; about 135 of these requests were granted, only to those planning to leave the service. It has granted thousands of exemptions for medical or administrative reasons. The Plaintiffs allege that the vaccine mandate substantially burdens their religious exercise in violation of the First Amendment and the Religious Freedom Restoration Act (RFRA). The district court granted a preliminary injunction that barred the Air Force from disciplining the Plaintiffs for failing to take a vaccine, then certified a class of thousands of similar service members and extended this injunction to the class.The Sixth Circuit affirmed. In opposing class-action certification, the Air Force argued that RFRA adopts an individual-by-individual approach: it must show that it has a compelling interest in requiring a “specific” individual to get vaccinated based on that person’s specific duties. In challenging the injunction, however, the Air Force failed to identify the specific duties or working conditions of any Plaintiff, citing the “general interests” underlying the mandate. The court reasoned that it could uphold the injunction based on RFRA alone but also noted common questions for the class: Does the Air Force have a uniform policy of relying on its generalized interests in the vaccine mandate to deny religious exemptions regardless of individual circumstances? Does it have a discriminatory policy of broadly denying religious exemptions but broadly granting secular ones? View "Doster v. Kendall" on Justia Law