Anderson v. Dooley

CourtDistrict Court, N.D. California
DecidedMarch 10, 2022
Docket4:15-cv-05120
StatusUnknown

This text of Anderson v. Dooley (Anderson v. Dooley) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. Dooley, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 BRUCE ANDERSON, et al., Case No. 15-cv-05120-HSG 8 Plaintiffs, ORDER RE CROSS-MOTIONS FOR SUMMARY JUDGMENT 9 v. Re: Dkt. Nos. 94, 121 10 MARK GHALY, in his official capacity as 11 Secretary of the CALIFORNIA DEPARTMENT OF HEALTH AND 12 HUMAN SERVICES 13 Defendant. 14 Three former California nursing home residents and an advocacy group brought this civil 15 rights lawsuit in November 2015 against the California Secretary of Health and Human Services 16 (“the Secretary”).1 Dkt. No. 1. They allege that the Secretary violated their federal rights by 17 failing to establish a “fair mechanism” for hearing nursing home residents’ transfer and discharge 18 appeals. See id. Discovery has now closed, and all parties have moved for summary judgment on 19 the question of the Secretary’s liability. See Dkt. Nos. 94 (“Sec. Mot.”) and 121 (“Pls. Mot.”). 20 Those motions are fully briefed.2 The Court held a hearing on the motions on November 18, 21 2021. Dkt. No. 129. Having carefully considered the parties’ arguments, the Court GRANTS the 22 Secretary’s motion and DENIES Plaintiffs’ motion. 23 24 25 1 Although Plaintiffs initially named former Secretary Diana Dooley as the defendant in this case, 26 her successor, Secretary Mark Ghaly, is automatically substituted as a party under Federal Rule of Civil Procedure 25(d). 27 2 See Dkt. Nos. 97 (“Opp. Sec. Mot.”), 98 (“Reply Sec. Mot.”), 123 (“Opp. Pls. Mot.”), 124 I. BACKGROUND 1 The individual plaintiffs who brought this case—Bruce Anderson, John Wilson, and 2 Robert Austin—are former residents of certified nursing homes in California.3 See Dkt. No. 1 ¶¶ 3 12-14. Each alleged that he was subject to “dumping,” which is when nursing homes send a 4 resident to a hospital for medical or mental health treatment but refuse to readmit them after they 5 have been discharged from the hospital. Pls. Mot. at 2-4. Plaintiffs maintain that because 6 Medicaid pays nursing homes less than Medicare or private insurance, nursing homes have a 7 strong incentive to dump residents that participate in Medicaid. Id. “Dumping,” they allege, is 8 “one of the greatest threats” nursing home residents in California face. Id. 9 Both federal and California law regulate nursing homes that participate in Medicaid. 10 Through the laws and regulations summarized below, both make it unlawful for a nursing home to 11 dump residents just because they seek to pay with Medicaid. 12 A. Federal Statutory and Regulatory Scheme 13 Medicaid is a cooperative federal-state program under which the federal government 14 provides funding to states to allow them to provide medical services to low-income persons. See 15 42 U.S.C. § 1396-1; see also Grammer v. John J. Kane Reg'l Centers-Glen Hazel, 570 F.3d 520, 16 523 (3d Cir. 2009). States are not required to participate in Medicaid, but those that do accept 17 federal funding must comply with the Medicaid Act and with regulations promulgated by the 18 Secretary of Health and Human Services. Grammer, 570 F.3d at 523. One of the services that 19 Medicaid funds is treatment at “nursing facilities,” also known as nursing homes or long-term care 20 facilities. See 42 U.S.C. § 1396d(a). 21 In 1987, Congress amended the Medicare and Medicaid Acts to provide more oversight of 22 nursing homes that participate in Medicare and Medicaid programs. See H.R. Rep. No. 100-391, 23 24 3 Sadly, both Mr. Wilson and Mr. Austin have passed away during this lawsuit. See Pls. Mot. at 6. 25 Because they no longer have Article III standing to pursue claims, the Court’s analysis will focus on Plaintiff Anderson’s claims. See LN Mgmt., LLC v. JPMorgan Chase Bank, N.A., 957 F.3d 26 943, 955 (9th Cir. 2020) (“We therefore join our sister circuits in holding that a party cannot maintain a suit on behalf of, or against, or join, a dead person, or in any other way make a dead 27 person (in that person’s own right, and not through a properly-represented estate or successor) 1 pt. 1, at 452; see also Grammer, 570 F.3d at 523. The resulting amendments, the Federal Nursing 2 Home Reform Amendments (“FNHRA”), require nursing homes to meet certain standards before 3 they can be reimbursed under Medicaid. Those requirements are codified at 42 U.S.C. § 1396r.4 4 FNHRA gave nursing home residents “[t]ransfer and discharge rights,” which it protects 5 by requiring nursing homes to meet certain conditions before they may lawfully transfer or 6 discharge a nursing home resident. Under FNHRA, a nursing home may only discharge a resident 7 for six reasons. Id. § 1396r(c)(2)(A).5 And if a nursing home does seek to transfer or discharge a 8 resident, it must first provide notice. Id. § 1396r(c)(2)(B). That notice must, among other 9 required information, inform the resident of her right to appeal the transfer or discharge. Id. § 10 1396r(c)(2)(B)(iii)(I). 11 FNHRA accordingly requires states to provide nursing home residents with a “fair 12 mechanism” for hearing appeals of their transfers and discharges. 42 U.S.C. § 1396(e)(3). A 13 state’s mechanism for hearing these appeals must meet “minimum standards” established through 14 regulation by the United States Secretary of Health and Human Services. 42 U.S.C. § 1396(f)(3). 15 4 Medicare, the federally-funded counterpart to Medicaid that provides health insurance to older 16 and disabled individuals, also provides coverage for nursing home services. See 42 U.S.C. § 1395d(a). FNHRA also amended the Medicare Act with substantially identical provisions. See id. 17 § 1395i-3. 5 Specifically, a nursing facility must permit each resident to remain in the facility and must not 18 transfer or discharge the resident from the facility unless:

19 (i) the transfer or discharge is necessary to meet the resident's welfare and the resident's welfare cannot be met in the facility; 20

(ii) the transfer or discharge is appropriate because the resident's 21 health has improved sufficiently so the resident no longer needs the services provided by the facility; 22

(iii) the safety of individuals in the facility is endangered; 23

(iv) the health of individuals in the facility would otherwise be 24 endangered;

25 (v) the resident has failed, after reasonable and appropriate notice, to pay (or to have paid under this subchapter or subchapter 26 XVIII on the resident's behalf) for a stay at the facility; or

27 (vi) the facility ceases to operate. 1 Those regulatory standards, in turn, require states to grant a hearing to any nursing home resident 2 who believes that a nursing home “erroneously determined” that she must be transferred or 3 discharged. 42 C.F.R. § 431.220(a)(2). The regulations also set forth procedural requirements for 4 the hearing itself. See id. §§ 431.240-.243. Ultimately, if the hearing decision is favorable, the 5 regulations require the relevant state agency to “promptly make corrective payments” and, “if 6 appropriate, provide for admission or readmission of an individual to a facility.” Id.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Department of Transportation v. Public Citizen
541 U.S. 752 (Supreme Court, 2004)
Davignon v. Clemmey
322 F.3d 1 (First Circuit, 2003)
Cafasso v. General Dynamics C4 Systems, Inc.
637 F.3d 1047 (Ninth Circuit, 2011)
Watson v. Weeks
436 F.3d 1152 (Ninth Circuit, 2006)
Already, LLC v. Nike, Inc.
133 S. Ct. 721 (Supreme Court, 2013)
Grammer v. John J. Kane Regional Centers-Glen Hazel
570 F.3d 520 (Third Circuit, 2009)
Kizer v. County of San Mateo
806 P.2d 1353 (California Supreme Court, 1991)
Shakur v. Schriro
514 F.3d 878 (Ninth Circuit, 2008)
State Department of Public Health v. Superior Court
342 P.3d 1217 (California Supreme Court, 2015)
Bishop Paiute Tribe v. Inyo County
863 F.3d 1144 (Ninth Circuit, 2017)
Twum v. Barr
930 F.3d 10 (First Circuit, 2019)
Bruce Anderson v. Michael Wilkening
930 F.3d 1066 (Ninth Circuit, 2019)
Jarman v. HCR ManorCare, Inc.
471 P.3d 1001 (California Supreme Court, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
Anderson v. Dooley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-dooley-cand-2022.