Idaho Department of Health & Welfare v. McCormick

283 P.3d 785, 153 Idaho 468, 2012 Ida. LEXIS 188
CourtIdaho Supreme Court
DecidedAugust 9, 2012
Docket38694
StatusPublished
Cited by15 cases

This text of 283 P.3d 785 (Idaho Department of Health & Welfare v. McCormick) is published on Counsel Stack Legal Research, covering Idaho Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Idaho Department of Health & Welfare v. McCormick, 283 P.3d 785, 153 Idaho 468, 2012 Ida. LEXIS 188 (Idaho 2012).

Opinion

J. JONES, Justice.

This appeal arises from a claim filed by the Idaho Department of Health and Welfare (the Department) in the probate proceeding of George D. Perry, the deceased spouse of a Medicaid recipient, Martha J. Perry. The Department sought to recover funds under I.C. § 56-218 from the sale of the couple’s home — their only significant asset — to recoup Medicaid benefits paid to Martha during her lifetime. The magistrate court disallowed the Department’s claim for recovery, finding that Martha had no interest in the real property because George, acting for Martha under a power of attorney, conveyed the property to himself before his death. That decision was upheld on appeal to the district court. The Department now appeals to this Court, and we reverse.

I.

FACTUAL AND PROCEDURAL HISTORY

This case stems from the probate of the estate of George D. Perry, who was born April 7, 1929, and died February 25, 2009. At the time of his death, George was married to Martha J. Perry, who was born November 13, 1930, and died May 3, 2010. Before George and Martha were married, Martha— then known as Martha Jean Boyle — owned a home in Ada County as her sole and separate property. On November 18, 2002, well into the couple’s marriage, Martha executed a Quitclaim Deed conveying the home to “Martha Jean Perry and George Donald Perry” as grantees. The deed was recorded that same day in Ada County.

On March 3, 2005, Martha executed a general durable power of attorney, naming George as her attorney-in-fact. On July 31, 2006, George conveyed Martha’s remaining interest in the couple’s real property to himself, signing a Quitclaim Deed on behalf of Martha using the power of attorney. The deed was recorded the same day. Around September 15, 2006, George and Martha applied to the Idaho Department of Health and Welfare for medical assistance to assist in Martha’s medical care. From October 1, 2006, until Martha’s death, the Department provided medical benefits of more than $100,000 to Martha through the Medicaid program.

On February 25, 2009, George predeceased Martha, and in March 2009, Barbara K. McCormick was appointed personal representative of his estate. The primary and only significant asset of the estate was the home, which was sold by the personal representative for a net of $81,688.95. In April 2009, the Department filed a contingent claim 1 with the probate court, seeking to establish a claim in the probate for funds in the amount of $106,251.08 for the Medicaid benefits provided to Martha. Specifically, *470 the Department claimed entitlement under 1.C. § 56-218 2 to “any property or estate which, at any time, had been the community property of the decedent and decedent’s spouse, or which had been the property of decedent’s spouse.” 3

The magistrate court denied the claim, finding that although I.C. § 56-218 allows the Department to recover against the estate of a Medicaid recipient’s spouse, such recovery is limited to “property in which the recipient spouse had an interest at the time of her death,” and that Martha validly conveyed her interest in the home to George via the power of attorney before that time. On appeal to the district court, the district court affirmed the magistrate court’s decision and declined to award attorney fees. The Department timely appealed to this Court.

II.

ISSUES ON APPEAL

I. Did the district court err in upholding the denial of the Department’s claim on the basis that, under I.C. § 56-218 and 42 U.S.C. § 1396p, the Department may only recover assets in which a Medicaid recipient has an interest at the time of her death?
II. Did the district court err in upholding the magistrate court’s determination that the general power of attorney executed by Martha gave George the power to convey her interest in the property to himself?
III. Is the Estate entitled to attorney fees on appeal?

III.

DISCUSSION

A. Standard of Review

“On appeal of a decision rendered by a district court while acting in its intermediate appellate capacity, this Court directly reviews the district court’s decision.” In re Doe, 147 Idaho 243, 248, 207 P.3d 974, 979 (2009). However, to determine whether the district court erred in affirming the magistrate court, independent review of the record before the magistrate court is necessary. Id. This Court reviews questions of law de novo. Martin v. Camas Cnty. ex rel. Bd. of Comm’rs, 150 Idaho 508, 511, 248 P.3d 1243, 1246 (2011). The interpretation of a statute is a question of law. State, Dep’t of Health and Welfare v. Housel, 140 Idaho 96, 100, 102, 90 P.3d 321, 325 (2004). Further, whether Idaho law is preempted by federal law is also a question of law. Christian v. Mason, 148 Idaho 149, 151, 219 P.3d 473, 475 (2009).

B. The district court erred in determining that, under I.C. § 56-218 and 42 U.S.C. § 1396p, the Department may only recover assets in which a Medicaid recipient has an interest at the time of her death.

Although the Department claimed entitlement under I.C. § 56-218 to recover “any property or estate which, at any time, had been the community property of [George and Martha], or which had been the property of [Martha],” the magistrate court found that its recovery was limited to property in which Martha had an interest at the time of her death. The magistrate court relied on a *471 Minnesota Supreme Court interpretation of definitions in the federal Medicaid recovery-statute as limiting the extent to which states may recover property transferred by the recipient before death. See In re Estate of Barg, 752 N.W.2d 52 (Minn.2008). On appeal, the district court agreed with that interpretation, finding that although Idaho law alone would allow recovery of the former community property here, such recovery would conflict with federal law and, thus, was preempted by federal law. On appeal to this Court, the Department argues that: no conflict exists between the plain language of Idaho and federal law, Barg does not apply, and this Court already disposed of this issue in Idaho Department of Health and Welfare v. Jackman, 132 Idaho 213, 970 P.2d 6 (1998).

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Bluebook (online)
283 P.3d 785, 153 Idaho 468, 2012 Ida. LEXIS 188, Counsel Stack Legal Research, https://law.counselstack.com/opinion/idaho-department-of-health-welfare-v-mccormick-idaho-2012.