Guardianship: Indiana Family & Social Services Administration v. Cheryl Adducci

CourtIndiana Court of Appeals
DecidedJuly 17, 2024
Docket23A-GU-02433
StatusPublished

This text of Guardianship: Indiana Family & Social Services Administration v. Cheryl Adducci (Guardianship: Indiana Family & Social Services Administration v. Cheryl Adducci) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Guardianship: Indiana Family & Social Services Administration v. Cheryl Adducci, (Ind. Ct. App. 2024).

Opinion

FILED Jul 17 2024, 9:23 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

IN THE

Court of Appeals of Indiana In Re the Guardianship of: Anthony Adducci, Incapacitated Person Indiana Family and Social Services Administration, Appellant-Intervenor

v.

Cheryl Adducci, Guardian for Anthony Adducci, Appellee-Petitioner

July 17, 2024 Court of Appeals Case No. 23A-GU-2433 Appeal from the Lake Superior Court The Honorable Calvin D. Hawkins, Judge Trial Court Cause No. 45D02-1905-GU-132

Opinion by Judge Bradford Judges Crone and Tavitas concur.

Court of Appeals of Indiana | Opinion 23A-GU-2433 | July 17, 2024 Page 1 of 15 Bradford, Judge.

Case Summary [1] In 2019, Cheryl Adducci was appointed guardian of her institutionalized

husband Anthony, applied for Medicaid coverage on his behalf, and (before

Anthony’s Medicaid application had been approved) petitioned to divert some

of his income for her support (“the Petition”), which petition the trial court

granted (in “the Support Order”). The Indiana Family and Social Services

Administration (“FSSA”) provisionally granted Anthony’s Medicaid

application and eventually moved to intervene in the case and for relief from

judgment, also arguing that the Support Order, which had the effect of

increasing the amount FSSA must pay for Anthony’s care, was unlawful. The

trial court denied FSSA’s motions to intervene and for relief from judgment and

reiterated that the Support Order was lawful.

[2] FSSA argues that it had a right to intervene in the action because the Support

Order diverted money to Cheryl that would have otherwise gone to pay

Anthony’s medical bills and it had no other way to challenge it. FSSA also

argues that it was entitled to relief from judgment because it was a necessary

party to the action who had not been served, rendering the Support Order void.

Finally, FSSA argues that the Support Order is without legal basis. Because we

agree with all of FSSA’s contentions, we reverse the trial court’s denials of

FSSA’s motions to intervene and for relief from judgment and remand with

instructions.

Court of Appeals of Indiana | Opinion 23A-GU-2433 | July 17, 2024 Page 2 of 15 Facts and Procedural History [3] On May 31, 2019, Cheryl was appointed guardian of her husband Anthony,

who had suffered a traumatic brain injury resulting in dementia and a brain

aneurysm, leaving him unable to care for himself or his assets. On June 17,

2019, Cheryl filed, inter alia, the Petition. On July 2, 2019, Cheryl applied for

Medicaid coverage on Anthony’s behalf. On July 16, 2019, the trial court

issued the Support Order, which allowed Cheryl to transfer up to $3275.00 of

Anthony’s income per month for her care, maintenance, and support. In

August of 2019, the Adduccis notified FSSA of the Support Order. On August

30, 2019, FSSA approved Anthony’s application for Medicaid coverage while

also noting that, prior to the Support Order, he had not been eligible for

Medicaid coverage because his income, as well as his and Cheryl’s resources,

exceeded applicable limits.

[4] On July 14, 2020, FSSA moved to intervene in the guardianship case and for

relief from judgment, arguing that it was a necessary party because the Support

Order meant that Indiana’s Medicaid program (which is administered by

FSSA) would have to pay for Anthony’s care and that it was entitled to relief

from judgment because it had not been served. During the litigation of FSSA’s

motions, FSSA also argued that the Support Order was unlawful because the

mandatory fair hearing in the FSSA had never occurred, the doctrine of

necessaries did not entitle Cheryl to spousal support, and Cheryl had violated

her fiduciary duty to Anthony. The Adduccis argued that FSSA (1) had not

moved for relief from judgment within a reasonable time, (2) had not been a

Court of Appeals of Indiana | Opinion 23A-GU-2433 | July 17, 2024 Page 3 of 15 necessary party to the guardianship proceedings, (3) and lacked standing to

claim that Cheryl had violated her fiduciary duty. The Adduccis also argued

that Indiana Code section 12-15-2-25 (“the State Medicaid Statute”) and the

doctrine of necessaries supported the Support Order.

[5] On September 14, 2023, the trial court denied FSSA’s motions to intervene and

for relief from judgment and, alternatively, concluded that FSSA was barred

from taking advantage of the equitable remedy of relief from judgment because

it had not engaged in mandatory rulemaking pursuant to Indiana Code section

12-15-2-25(d) and, therefore, had unclean hands. The trial court also concluded

that Cheryl’s allowance was supported by the State Medicaid Statute and the

doctrine of necessaries.

Discussion and Decision I. Background [6] In the Medicaid program, the federal government provides funding to states,

which in turn reimburse qualifying individuals for the cost of medical care.

Wis. Dep’t of Health & Fam. Servs. v. Blumer, 534 U.S. 473, 479 (2002) (citing

Schweiker v. Gray Panthers, 453 U.S. 34, 36–37 (1981)). For institutionalized

individuals, Medicaid starts with the presumption that the individual must pay

all of his income, minus certain permitted deductions, to the institutions caring

for him before he can qualify for assistance. See Lowes v. Lowes, 650 N.E.2d

1171, 1175 (Ind. Ct. App. 1995) (“Congress intended that all third party sources

of income to which an applicant is entitled be exhausted before resort to the

social welfare system.”). Court of Appeals of Indiana | Opinion 23A-GU-2433 | July 17, 2024 Page 4 of 15 [7] It was eventually realized that this exhaustion requirement, at times, left the

community spouse1 with insufficient resources, which prompted Congress to

pass the Medicare Catastrophic Coverage Act of 1988 (“the MCCA”). 42

U.S.C. § 1396r-5. The stated purpose of the MCCA was to “end th[e]

pauperization of the community spouse by assuring that the community spouse

has a sufficient—but not excessive—amount of income and resources

available[.]” Blumer, 534 U.S. at 480. In some cases, an institutionalized

spouse is permitted to transfer a “community spouse monthly income

allowance” without that amount being counted against him for eligibility-

determination purposes. 42 U.S.C. § 1396r-5(d)(3). The exact amount of the

monthly income allowance is determined by subtracting a community spouse’s

actual monthly earnings from a “minimum monthly maintenance needs

allowance” (“the Allowance”), which is set by the State. 42 U.S.C. § 1396r-

5(d)(2)–(3). If this calculation results in a shortfall between the community

spouse’s monthly income and the Allowance, the community spouse’s monthly

income allowance becomes the difference between the two amounts. 42 U.S.C.

§ 1396r-5(d)(2).

[8] Either spouse may petition for a “fair hearing before the State agency[,]” i.e.,

FSSA, to argue that the Allowance should be increased. 42 U.S.C. § 1396r-

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