Doherty v. Director of the Office of Medicaid

31 Mass. L. Rptr. 369
CourtMassachusetts Superior Court
DecidedAugust 14, 2013
DocketNo. ESCV201300457D
StatusPublished

This text of 31 Mass. L. Rptr. 369 (Doherty v. Director of the Office of Medicaid) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Doherty v. Director of the Office of Medicaid, 31 Mass. L. Rptr. 369 (Mass. Ct. App. 2013).

Opinion

Ullmann, Robert L., J.

A reformed trust can turn back the clock on certain legal decisions. However, it cannot resurrect the departed. Armed with a newly reformed trust instrument, plaintiffs have asked the Commonwealth’s Executive Office of Health and Human Services (“EOHHS”) to reconsider its 2006 denial of Medicaid benefits to their deceased aunt, and reimburse them nearly $400,000 that their aunt paid to a nursing home. For reasons explained below, plaintiffs far-too-clever effort to obtain Medicaid funds must be denied, as they lack standing to apply for benefits.

Background

In 1981, Muriel S. Doherty (“Doherty”) and her husband established the William A. Doherty and Muriel S. Doherty Family Trust. On April 12, 2000, after her husband’s death, Doherty amended and restated [370]*370the trust .and changed its name to the Muriel S. Doherty Irrevocable Family Trust (the ‘Trust”).

In 2006, after moving into a North Andover nursing home, Doherty applied to EOHHS for Medicaid benefits, which EOHHS provides through the MassHealth program. EOHHS denied the application on the grounds that Doherty’s assets, which included the Trust, far exceeded the maximum allowable in order to qualify for benefits. Doherty appealed EOHHS’s ruling, which ultimately resulted in an Appeals Court decision upholding the agency’s decision. Doherty v. Director of the Office of Medicaid, 74 Mass.App.Ct. 439 (2009). The Appeals Court described the case as an example of:

the conflict between the Legislature’s explicit direction that Medicaid benefits be made available only to people who do not have sufficient income or resources to provide for themselves . . . and the desire of persons with some means, perhaps even considerable means, to preserve their assets in the face of the large medical expenses faced ... by elderly persons.

74 Mass.App.Ct. at 439. The Appeals Court held that EOHHS had lawful grounds to include the Trust’s principal as Doherly assets because the Trust instrument allowed Doherty’s trustees to distribute the trust principal to her under some circumstances. Id. at 442. The Court observed that Doherty’s argument would permit her to “enjoy her assets, preserve those assets for her heirs, and receive public assistance, to, in effect, ‘have [her] cake and eat it too.’ ” Id. at 443, quoting Cohen v. Commissioner of the Div. of Med. Assistance, 423 Mass. 399, 403 (1996), cert, denied sub nom. Kokoska by Kokoska v. Bullen, 519 U.S. 1057 (1997) (additional citation omitted).

As one consequence of EOHHS’s denial of benefits, Doherty paid $382,592.98 to the North Andover nursing home between late 2005 and the time of her death, which occurred in July 2010.

In November 2010, plaintiffs, the co-trustees and sole beneficiaries of the Trust, filed a complaint in Probate & Family Court seeking to reform the Trust (the “Probate Case”). The sole defendants in the Probate Case were plaintiffs, in their individual capacities. Plaintiffs alleged that Doherty had intended that the trustees have no discretionaiy authority to distribute trust principal to her under any circumstances, and that any contrary language in the Trust was a “scrivener’s error.”

Plaintiffs moved for summary judgment in the Probate Case in April 2011. A hearing was held on May 4, 2011 before Judge Mary. McCauley Manzi. Two weeks later, Judge Manzi denied the requested relief, based on the prior Appeals Court decision.1 In October 2011, plaintiffs moved for reconsideration of Judge Manzi’s ruling, arguing that the Appeals Court decision should not have a res judicata effect on the Probate case. On November 9, 2011, plaintiffs motion for reconsideration was denied.

Thereafter, on January 17, 2012, plaintiffs filed a Stipulation of Judgment for reformation of the Trust in the Probate Case. The sole parties to the stipulation were the plaintiffs as co-trustees of the Trust and the plaintiffs in their individual capacities. That same day, a second Probate & Family Court judge entered a Judgment reforming the Trust ab initio as of April 12, 2000 (the “Judgment”), thereby establishing a new trust instrument (the “Reformed Trust”). Plaintiffs acknowledged at the hearing on the motion before this Court that, in entering judgment, the probate court judge did not address any intended use of the Reformed Trust in a future proceeding.

In November 2012, plaintiffs presented the Reformed Trust to EOHHS, demanding that EOHHS reconsider its 2006 denial of benefits to Doherly under the Reformed Trust and pay them the full amount of money that Doherty had paid to the North Andover nursing home. EOHHS refused to consider plaintiffs’ application for benefits. In December 2012, defendant informed plaintiffs that the Reformed Trust did not provide grounds to reopen its 2006 eligibility determination, and that “a probate action allowing the reformation of a trust is not binding on the MassHealth Agency or its eligibility determination.”

In response, plaintiffs filed the pending lawsuit, seeking a declaration from this Court that MassHealth must recognize the Judgment, reconsider Doherty’s request for benefits under the Reformed Trust, and render a decision. Defendant moved to dismiss the Complaint under Mass.R.Civ.P. 12(b)(1) for lack of subject matter jurisdiction, on the dual grounds that plaintiffs lack standing and that there is no actual controversy. The Court held a hearing on July 23, 2013.

Legal Analysis

Defendant argues that plaintiffs’ complaint must be dismissed pursuant to Mass.R.Civ.P. 12(b)(1) because there is no actual controversy and because plaintiffs lack standing to sue EOHHS. The Court holds that plaintiffs lack standing to sue EOHHS over the 2006 denial of benefits to Doherly, and does not address the actual controversy argument. As discussed below, plaintiffs’ argument has a fatal Achilles Heel, which is that the MassHealth Medicaid program exists to provide health benefits to indigent persons, not to enrich heirs who concededly do not qualify for benefits.

The Supreme Judicial Court has made clear that “[a] party has standing when it can allege an injury within the area of concern of the statute or regulatory scheme under which the injurious action has occurred.” Enos v. Secretary of Environmental Affairs, 432 Mass. 132, 135 (2000) (property owners lack standing to challenge agency’s decision concerning town’s plans to build sewage treatment facility). See also Ineck Maine Energy, LLC v. Commissioner of [371]*371Energy Resources, 454 Mass. 511, 517 (2009) (owners of competing renewable energy facilities have.no standing to challenge agency decision allowing other facilities to participate in agency program); Northbridge v. Natick; Department of Social Services, 394 Mass. 70, 75 (1985) (town could not rely on language in interagency agreement regarding payment of costs for special education services because agencies “entered into the agreement in order to facilitate delivery of services to special needs children in their custody and to allocate costs among themselves, not to aid local education authorities”). In addition, in lawsuits against a public entity, the Supreme Judicial Court has stated that it pays “special attention to the requirement that standing usually is not present unless the governmental official or agency can be found to owe a duty directly to the plaintiffs.”

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Related

Town of Northbridge v. Town of Natick Department of Social Services
474 N.E.2d 551 (Massachusetts Supreme Judicial Court, 1985)
Cohen v. Commissioner of the Division of Medical Assistance
423 Mass. 399 (Massachusetts Supreme Judicial Court, 1996)
Enos v. Secretary of Environmental Affairs
432 Mass. 132 (Massachusetts Supreme Judicial Court, 2000)
Indeck Maine Energy, LLC v. Commissioner of Energy Resources
454 Mass. 511 (Massachusetts Supreme Judicial Court, 2009)
Bay Colony Marketing Co. v. Fruit Salad, Inc.
672 N.E.2d 987 (Massachusetts Appeals Court, 1996)
Commonwealth v. Taylor
868 N.E.2d 1273 (Massachusetts Appeals Court, 2007)
Doherty v. Director of the Office of Medicaid
908 N.E.2d 390 (Massachusetts Appeals Court, 2009)
Kokoska ex rel. Kokoska v. Bullen
519 U.S. 1057 (Supreme Court, 1997)

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Bluebook (online)
31 Mass. L. Rptr. 369, Counsel Stack Legal Research, https://law.counselstack.com/opinion/doherty-v-director-of-the-office-of-medicaid-masssuperct-2013.