Coe v. DC Department of Human Services

CourtDistrict of Columbia Court of Appeals
DecidedSeptember 1, 2022
Docket17-AA-590
StatusPublished

This text of Coe v. DC Department of Human Services (Coe v. DC Department of Human Services) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Coe v. DC Department of Human Services, (D.C. 2022).

Opinion

Notice: This opinion is subject to formal revision before publication in the Atlantic and Maryland Reporters. Users are requested to notify the Clerk of the Court of any formal errors so that corrections may be made before the bound volumes go to press.

DISTRICT OF COLUMBIA COURT OF APPEALS No. 17-AA-590 EBONY COE, PETITIONER, V.

DISTRICT OF COLUMBIA DEPARTMENT OF HUMAN SERVICES, RESPONDENT. On Petition for Review of an Order of the District of Columbia Office of Administrative Hearings (DHS-859-16)

(Argued May 16, 2019 Decided September 1, 2022)

Chelsea Sharon, Legal Aid Society for the District of Columbia, with whom David Carpman, Jonathan H. Levy, and Jennifer Mezey, Legal Aid Society for the District of Columbia, were on the brief, for petitioner.

Richard S. Love, Senior Assistant Attorney General, with whom Karl A. Racine, Attorney General for the District of Columbia, Loren L. AliKhan, Solicitor General at the time the brief was filed, and Caroline S. Van Zile, Deputy Solicitor General, were on the brief, for respondent.

Before BECKWITH, Associate Judge, and RUIZ and FISHER, ∗ Senior Judges.

Opinion of the court by Associate Judge BECKWITH.

Dissenting opinion by Senior Judge FISHER at page 12.

∗ Judge Fisher was an Associate Judge at the time of argument. His status changed to Senior Judge on August 23, 2020. 2

BECKWITH, Associate Judge: In early December 2016, the District of

Columbia Department of Human Services (DHS) notified petitioner Ebony Coe

that her Medicaid benefits would be terminated at the end of the month. Ms. Coe

appealed the agency’s determination to the Office of Administrative Hearings

(OAH). She argued that DHS erred in terminating her benefits and that the error

was part of an unlawful policy of terminating Medicaid coverage without

conducting the pretermination assessment required by federal law. An

Administrative Law Judge (ALJ) found that DHS erroneously terminated Ms.

Coe’s benefits due to a misapplication of federal law, but ruled that he lacked

authority to order the mayor to correct the unlawful policy. He determined that

such an order could be issued only by a judge of the Superior Court upon a request

for equitable relief made in that court. DHS argues that this is a proper

interpretation of the relevant statutes and Ms. Coe contends that it is not. We agree

with Ms. Coe and we reverse and remand for further proceedings.

I.

States that participate in Medicaid must comply with federal requirements in

administering the program. See Naccache v. Taylor, 199 A.3d 181, 187 (D.C. 3

2018). 1 Medicaid provides health care benefits to, among others, people who are

“aged, blind, or disabled,” as well as people whose Modified Adjusted Gross

Income (MAGI) falls below a certain level. See 42 U.S.C. § 1396-1. Some people

qualify for Medicaid under more than one provision. The District must reevaluate

the eligibility of individuals who are enrolled in Medicaid due to disability at least

every twelve months. See 42 C.F.R. § 435.916(b). Before terminating an enrolled

person from Medicaid, the Department of Human Services (DHS) “must consider

all bases of eligibility.” Id. § 435.916(f)(1). Until DHS has found an enrolled

individual to be ineligible, it must “[c]ontinue to furnish Medicaid regularly” to

that person. 42 C.F.R. § 435.930(b).

Ms. Coe was receiving Medicaid coverage due to her disability when she

received a notice that she would “not be eligible for medical assistance of any

type” as of January 2017 because she was “neither aged or disabled.” The notice

also stated, “[Y]ou can apply for Medicaid at DC Health Link.” Believing that she

might qualify for Medicaid based on her MAGI, Ms. Coe began the online DC

Health Link application. She was stopped by an error message that said she could

not apply because she had active Medicaid coverage. A DHS caseworker

1 The term “state” includes the District of Columbia. See 42 C.F.R. § 400.203 (2021). 4

confirmed that she could not apply until her current benefits expired, and a DHS

supervisor suggested that she apply once her disability-based coverage ended.

Ms. Coe filed a request for a hearing with OAH, seeking reversal of the

agency’s termination decision on the ground that DHS had failed to screen her for

MAGI eligibility as it was legally required to do. She also requested an order

pursuant to D.C. Code § 4-210.16 directing DHS to correct its policy of

terminating non-MAGI Medicaid coverage without conducting the necessary

pretermination review of MAGI eligibility. DHS conceded that it failed to

evaluate alternate bases for Ms. Coe’s Medicaid eligibility because of a

“technological barrier”—namely, a “built-in failsafe to prevent fraud and duplicate

case creation.” DHS asserted that it would address cases “on an ad-hoc basis as

they are brought to the Agency’s attention” while it modified the certification

process. DHS also stated that it would help Ms. Coe obtain a determination of her

income-based eligibility and “ensur[e] that she [would] not experience a break in

coverage” if she still qualified for Medicaid.

The ALJ reversed DHS’s termination of Ms. Coe’s benefits because DHS

violated Ms. Coe’s right under 42 C.F.R. § 435.930(b) to receive benefits until

“found to be ineligible.” The ALJ also found that the termination was “based on ‘a

misapplication of law’ within the meaning of [s]ection 4-210.16.” It declined, 5

however, to issue an order directing the mayor to take corrective action. Stating

that ALJs have “expressly-defined statutory and regulatory powers” that are

distinct from the “broad, equitable powers of a court,” the ALJ concluded that an

order directing the mayor to correct the unlawful policy would constitute “purely

declaratory relief that may overstep the boundaries of [his] authority as an

administrative law judge.”

II.

On petition for review, Ms. Coe argues that D.C. Code § 4-210.16(b) gives

ALJs authority to issue an order directing the mayor to correct a policy that does

not comply with federal law. DHS counters that § 4-210.16(b) does not confer

such authority and that in the absence of explicit statutory authorization, ALJs are

limited to sustaining or reversing a mayoral action. 2

“The proper construction of a statute raises a question of law, and our review

is de novo.” Washington v. District of Columbia Dep’t of Pub. Works, 954 A.2d

945, 948 (D.C. 2008). “Because the OAH is simply an all-purpose adjudicatory

body, without a particular subject-matter focus, its legal interpretations do not

command deference.” United Dominion Mgmt. Co. v. District of Columbia Rental

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

Related

Monsanto Co. v. Geertson Seed Farms
561 U.S. 139 (Supreme Court, 2010)
Morris v. United States Environmental Protection Agency
975 A.2d 176 (District of Columbia Court of Appeals, 2009)
School Street Associates Ltd. Partnership v. District of Columbia
764 A.2d 798 (District of Columbia Court of Appeals, 2001)
District of Columbia v. Wical Ltd. Partnership
630 A.2d 174 (District of Columbia Court of Appeals, 1993)
Ramos v. District of Columbia Department of Consumer & Regulatory Affairs
601 A.2d 1069 (District of Columbia Court of Appeals, 1992)
Badawi v. Hawk One Security, Inc.
21 A.3d 607 (District of Columbia Court of Appeals, 2011)
District of Columbia Office of Tax and Revenue v. John R. Shuman and Sara G. Shuman
82 A.3d 58 (District of Columbia Court of Appeals, 2013)
United Dominion Management Co. v. District of Columbia Rental Housing Commission
101 A.3d 426 (District of Columbia Court of Appeals, 2014)
Board of Directors v. Board of Trustees
798 A.2d 1068 (District of Columbia Court of Appeals, 2002)
Paschall v. District of Columbia Department of Health
871 A.2d 463 (District of Columbia Court of Appeals, 2005)
Williams v. District of Columbia Department of Public Works
65 A.3d 100 (District of Columbia Court of Appeals, 2013)
Naccache v. Taylor
199 A.3d 181 (District of Columbia Court of Appeals, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Coe v. DC Department of Human Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coe-v-dc-department-of-human-services-dc-2022.