Patel v. Sudders

34 Mass. L. Rptr. 21
CourtMassachusetts Superior Court, Suffolk County
DecidedDecember 29, 2016
DocketNo. SUCV20163533G
StatusPublished

This text of 34 Mass. L. Rptr. 21 (Patel v. Sudders) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court, Suffolk County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patel v. Sudders, 34 Mass. L. Rptr. 21 (Mass. Super. Ct. 2016).

Opinion

Wilson, Paul D., J.

Plaintiff is a dentist, 41% of whose patients are participants in MassHealth, the state’s Medicaid program. Defendants (collectively “MassHealth”) are state officials charged with administering MassHealth, and in particular the provision of dental services to MassHealth participants.

Plaintiff is being prosecuted criminally for indecent assault on female patients. When MassHealth learned of this prosecution, it notified Plaintiff by letter dated October 6, 2016 that it was terminating his participation in the MassHealth dental program in order to protect the health, welfare, and safely of MassHealth members. MassHealth’s letter informed Plaintiff that in order to protect his right to a post-termination adjudicatory hearing, he needed to file a reply within 30 days, which he did. MassHealth reviewed that response, and issued a Final Determination Notice on December 9, 2016 that finalized his termination from the MassHealth program. The Final Determination Notice informed Plaintiff of his right to claim an adjudicatory hearing within the next 30 days.3

On November 17, 2016, Plaintiff filed this lawsuit. Along with his complaint, he filed an emergency motion for a temporary restraining order and preliminary injunction and a supporting brief. The clerk issued a short order of notice scheduling a hearing for Wednesday, November 23, 2016, over which I presided. At that hearing, the Assistant Attorney General representing MassHealth pointed out that plaintiff had failed to comply with Mass.RCiv.P. 4(d)(3) by serving the Attorney General as well as MassHealth, and therefore she had only known about the lawsuit, and the injunction request, for about 48 hours. The Assistant Attorney General requested an opportunity to prepare and file a brief, which I allowed, and then I allowed Plaintiffs request to file a supplemental brief. I established a briefing schedule that accounted for the fact that the next day was Thanksgiving. I then heard extensive oral argument, during which both parties presented me with various cases and regulations.

On December 7, 2016, Plaintiff filed his supplemental brief, as well as an amended complaint. The Mass-Health opposition brief was docketed on December 16, 2016. I have reviewed the extensive briefing; many of the statutes, regulations and cases (from Massachusetts and elsewhere) cited in those briefs; and the factual materials submitted by both parties. I will now deny Plaintiffs request for injunctive relief.

Discussion

The three requirements for a preliminary injunction are well known. The moving party must show “(1) a likelihood of success on the merits; (2) that irreparable harm will result from denial of the injunction; and (3) that, in light of the [moving party’s] likelihood of success on the merits, the risk of irreparable harm to the [moving party] outweighs the potential harm to the [opposing party] in granting the injunction.” Loyal Order of Moose, Inc., Yarmouth Lodge #2270 v. Bd. of Health of Yarmouth, 439 Mass. 597, 601 (2003); quoting Tri-Nel Mgt., Inc. v. Bd. of Health of Barnstable, 433 Mass. 217, 219 (2001).

When a party seeks to enjoin governmental action, a fourth factor becomes relevant: the court “must also consider whether the grant of an injunction would adversely affect the public interest.” Student No. 9 v. Bd. of Educ., 440 Mass. 752, 762 (2004); accord, Commonwealth v. Mass. CRINC, 392 Mass. 79, 89 (1984). If the governmental body has determined “that the public interest is better served” by the action that the moving parly seeks to enjoin, the agency’s determination “should not be second guessed by a court” unless the moving party shows that the government agency has engaged in “illegal or arbitrary action.” Stemens Bldg. Techs., Inc. v. Div. of Capital Asset Mgmt., 439 Mass. 759, 765 (2003).

1. Likelihood of Success on the Merits

Plaintiffs amended complaint, like his original complaint, includes two claims, for breach of contract [22]*22and for violation of his due process rights. The parties’ arguments largely focus on the due process claims, perhaps because a due process violation is more likely to be deemed an “illegal or arbitrary action,” as Siemens put it, than is a breach of contract. So I will first analyze Plaintiffs likelihood of success on the merits as to that claim.

a. The Due Process Claim

As Plaintiff correctly states in his opening brief, the due process clause applies to any “significant deprivation of liberty or property ... at the state’s hands.” Plaintiffs Brief of November 17, 2016 at 7, quoting Gonzales-Droz v. Gonzales-Colon, 660 F.3d 1, 13 (1st Cir. 2011) (additional citation omitted). A due process analysis begins, therefore, with question of whether the state has deprived the complaining party of a liberty or property right.

A property right protected by the due process clause arises from “existing rules or understandings that stem from an independent source such as state law— rules or understandings that secure certain benefits and that support claims of entitlement to those benefits.” Bd. of Regents v. Roth, 408 U.S. 564, 577 (1972). At oral argument, Plaintiff conceded that there is no Massachusetts case law stating that a MassHealth provider has a property interest in his provider status. Nor does Plaintiff point to anything in the regulations that govern the MassHealth program that suggest that any provider has a property interest in continued participation in the MassHealth program. The property interest arises nonetheless, Plaintiff suggested at oral argument, from the simple fact that he has a contractual relationship with the MassHealth program.

For nearly 40 years, federal courts have been ruling that doctors, dentists and other providers of medical care do not have a property interest in continued participation in the Medicaid or Medicare programs. The earliest such case, in fact, arose in the First Circuit. Cervoni v. Sec’y of Health, Educ. & Welfare, 581 F.2d 1010, 1018, 1019-20 (1st Cir. 1978) (a physician did not “have a current valid expectation, based on the Government’s implied promise to continue an entitlement, in an important, personal, monetizable interest,” because to “engraft upon the [Medicare] system a concept of ‘accrued properly rights’ would deprive it of the flexibility and boldness in adjustment to ever-changing conditions which it demands”). Among the more recent federal appellate cases is Guzman v. Shewry, 552 F.3d 941, 953 (9th Cir. 2009) (providers have no protected property interest in “continued participation in Medicare, Medicaid, or the federally-funded state healthcare programs”). On pages 11 through 13 of its brief, MassHealth cites many more federal appeals court and district court cases that reach the same conclusion. On those pages of its brief, MassHealth also cites a few cases that, to the contrary, did find a property interest in continued participation in such programs, often based on peculiarities of the applicable state law. See, e.g., Snodgrass-King Pediatric Dental Assoc., P.C. v. Dentaquest USA Ins., 79 F.Sup.3d 753 (M.D.Tenn.

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Board of Regents of State Colleges v. Roth
408 U.S. 564 (Supreme Court, 1972)
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466 N.E.2d 792 (Massachusetts Supreme Judicial Court, 1984)
Eduardo Guzman v. Sandra Shewry
552 F.3d 941 (Ninth Circuit, 2009)
Tri-Nel Management, Inc. v. Board of Health
433 Mass. 217 (Massachusetts Supreme Judicial Court, 2001)
Loyal Order of Moose, Inc., Yarmouth Lodge 2270 v. Board of Health
790 N.E.2d 203 (Massachusetts Supreme Judicial Court, 2003)
Siemens Building Technologies, Inc. v. Division of Capital Asset Management
791 N.E.2d 340 (Massachusetts Supreme Judicial Court, 2003)
Student No. 9 v. Board of Education
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González-Droz v. González-Colón
660 F.3d 1 (First Circuit, 2011)

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Bluebook (online)
34 Mass. L. Rptr. 21, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patel-v-sudders-masssuperctsuff-2016.