Givens v. Bowser

CourtDistrict Court, District of Columbia
DecidedSeptember 30, 2022
DocketCivil Action No. 2020-0307
StatusPublished

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

Bluebook
Givens v. Bowser, (D.D.C. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

EVA MAE GIVENS,1

Plaintiff,

v. Civil Action No. 20-307 MURIEL BOWSER, in her official (EGS/ZMF) capacity as Mayor, Washington, D.C., et al.,

Defendants.

MEMORANDUM OPINION

I. Introduction

Plaintiff Eva Mae Givens (“Ms. Givens”) filed this action

against Defendants Muriel Bowser, in her official capacity as

Mayor of Washington, D.C.; Laura Green Zeilinger, in her

official capacity as Director2 of the District of Columbia

Department of Human Services; Wayne Turnage, in his official

capacity as Director of the District of Columbia Department of

1 Magistrate Judge Faruqui granted the motion of Eugene P. Givens, Jr., Deborah R. Bowser, and Anthony D. Givens (collectively, “Plaintiffs”) to substitute as Plaintiffs for the limited purpose of objecting to the Report and Recommendation, ECF No. 28. See Minute Order (June 16, 2021). 2 The First Amended Complaint sues the “Commissioner” of the

District of Columbia Department of Human Services, but there is no such position. See First Am. Compl., ECF No. 1 at 1; see also Meet Our Executive Team, Dep’t of Hum. Servs., https://dhs.dc.gov/page/meet-our-executive-team-. 1 Health Care Finance; and M. Colleen Currie,3 in her official

capacity as Chief Administrative Law Judge of the District of

Columbia Office of Administrative Hearings (collectively,

“Defendants”). See First Am. Compl. (“Am. Compl.”), ECF No. 16.

Ms. Givens sues these officials under 42 U.S.C. § 1983 (“Section

1983”) on behalf of herself individually and two similarly

situated classes of individuals, requesting declaratory and

injunctive relief as well as monetary damages, and alleging that

Defendants have a policy and/or practice of: (1) failing to

properly deduct expenses incurred by Medicaid applicants and

recipients; and (2) failing to render Medicaid fair hearing

decisions within 90 days. See id. at 2 ¶ 4; id. at 12 ¶¶ 46-49.4

On July 1, 2020, Defendants moved to dismiss the action.

See generally Defs.’ Mot. Dismiss Pl.’s First Am. Compl., ECF

No. 18. On October 13, 2020, the Court referred the matter to

Magistrate Judge Faruqui for full case management, up to but

excluding trial pursuant to Local Civil Rule 72.2. See Minute

Order (Oct. 13, 2020). Magistrate Judge Faruqui has since issued

a Report & Recommendation (“R. & R.”) recommending that the

3 Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, the current Chief Administrative Law Judge, M. Colleen Currie, is substituted as Defendant for the former Chief Administrative Law Judge, Eugene A. Adams. See Fed. R. Civ. P. 25(d). 4 When citing electronic filings throughout this Opinion, the

Court refers to the ECF page numbers, not the page numbers of the filed documents. 2 Court grant Defendants’ Motion to Dismiss. See R. &. R., ECF No.

28.

Pending before the Court are Plaintiffs’ Objections to

Magistrate Judge Faruqui’s R. & R. See Objs. by Eugene P.

Givens, Jr., Deborah R. Bowser and Anthony D. Givens to

Magistrate Judge Zia M. Faruqui’s May 3. 2021 R. & R. (“Pls.’

Objs.”), ECF No. 33. Upon careful consideration of the R. & R.,

the objections and opposition thereto, the applicable law, and

the entire record herein, the Court hereby ADOPTS the R. & R,

see ECF No. 28; and GRANTS Defendants’ Motion to Dismiss, see

ECF No. 18.

II. Background

A. Medicaid Eligibility

The R. &. R. sets forth the statutory and regulatory

background as follows:

Congress passed the Medicaid Act in 1965 and established a “cooperative” arrangement between the federal government and the States through which poor and medically vulnerable Americans receive healthcare benefits. Wilder v. Va. Hosp. Ass’n, 496 U.S. 498, 502 (1990). States must create and administer their own plan in accordance with federal law; in exchange, the Federal government funds their Medicaid programs. See 42 U.S.C. § 1396a(a). Each State submits its Medicaid plan to the Department of Health and Human Services for approval. See 42 U.S.C. § 1396a(b). The plan must include information about the proposed process and criteria for determining Medicaid eligibility, two categories of which are

3 relevant here. See 42 U.S.C. § 1396a(e)(14)(E). The first includes individuals who are “categorically needy,” that is, those individuals who are eligible solely because of their low income. Md. Dept. of Health & Mental Hygiene v. Ctrs. for Medicare & Medicaid Servs., 542 F.3d 424, 429 (4th Cir. 2008) (citing 4 U.S.C. § 1396a(a)(10)). The second is made up of “medically needy” individuals—those who “have become impoverished through medical expenditures; while they have sufficient income to afford basic living expenses, they cannot afford expensive medical care.” Id.

“If a medically needy applicant’s pre- eligibility income exceeds the Medicaid limit,” States are “to deduct incurred medical expenses in order to reduce that income to the Medicaid eligibility level.” Id. (citing 42 C.F.R. § 435.831(d)). In making this calculation, States make “standard deductions” from an applicant’s income. Id. If an applicant’s post-deduction income is at or below the Medicaid threshold, the individual is eligible for Medicaid enrollment. See 42 C.F.R. § 435.831(f); 29 D.C.M.R. § 9899. After these “spend down” adjustments are made for a medically needy applicant, the state Medicaid plan is required to calculate the amount of income the applicant is expected to contribute to her medical expenses. See 42 C.F.R. § 435.725(a). “[N]ursing home residents with income remaining after the completion of the spenddown process” must contribute their “excess” income to the nursing home “to defray the cost of their care.” Md. Dep’t of Health, 542 F.3d at 430 (citing 42 C.F.R. § 435.725(a)). This cost-sharing system between the State Medicaid plan and the covered individual operates like a co-pay, and the amount the beneficiary owes is determined after states make certain mandatory deductions, including deductions of medical expenses incurred prior to the eligibility

4 determination. See 42 U.S.C. § 1396a(r)(1)(A)(ii).

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