SINAI CENTER FOR REHABILITATION AND HEALTHCARE, LLC v. NEW JERSEY DEPARTMENT OF HEALTH

CourtDistrict Court, D. New Jersey
DecidedSeptember 30, 2025
Docket3:24-cv-09465
StatusUnknown

This text of SINAI CENTER FOR REHABILITATION AND HEALTHCARE, LLC v. NEW JERSEY DEPARTMENT OF HEALTH (SINAI CENTER FOR REHABILITATION AND HEALTHCARE, LLC v. NEW JERSEY DEPARTMENT OF HEALTH) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SINAI CENTER FOR REHABILITATION AND HEALTHCARE, LLC v. NEW JERSEY DEPARTMENT OF HEALTH, (D.N.J. 2025).

Opinion

NOT FOR PUBLICATION

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY SINAI CENTER FOR REHABILITATION AND HEALTHCARE, LLC, Plaintiff, Civil Action No. 24-9465 (ZNQ) (RLS) v. OPINION NEW JERSEY DEPARTMENT OF HEALTH and KAITLAN BASTON in her official capacity as the Commissioner for the New Jersey Department of Health, Defendants. QURAISHI, District Judge THIS MATTER comes before the Court upon a Motion to Dismiss filed by the New Jersey Department of Health (“DOH”) and Commissioner Kaitlan Baston (“Commissioner”) (collectively, “Defendants”). (“Motion,” ECF No. 14; see “Moving Br.”, ECF No. 14-1.) Plaintiff Sinai Center for Rehabilitation and Healthcare, LLC (“Sinai”) filed opposition (“Opp’n Br.”, ECF No. 16), to which Defendants replied (ECF No. 17). The Court has carefully considered the parties’ submissions and decides the Motion without oral argument pursuant to Federal Rule of Civil Procedure 78 and Local Civil Rule 78.1. For the reasons set forth below, Defendants’ motion is both GRANTED IN PART and DENIED IN PART. I. BACKGROUND AND PROCEDURAL HISTORY A. FACTUAL BACKGROUND 1 Sinai seeks a declaration that New Jersey law, N.J.S.A. 26:2H-128 and N.J.A.C. 8:39-4.1, violates the Supremacy Clause of the United States Constitution. (Opp’n Br. at 1; see generally Compl.)

1. The Parties Sinai is a limited liability corporation that operates an accredited skilled nursing facility (“SNF”) and provides skilled nursing care for individuals with medical issues that require around- the-clock care. (Compl. ¶¶ 3–4.) DOH is an official department of the State of New Jersey. (Id. ¶ 7.) DOH aims to improve the “‘well-being and quality of life for all New Jerseyans’ by ‘providing essential services and implementing comprehensive measures that prioritize public health.’” (Id. ¶ 8.) DOH also drafts, implements, and enforces various regulations that apply to skilled nursing facilities such as Sinai. (Id. ¶ 9.) Baston was the Commissioner of DOH at the time the Motion was filed. The

Commissioner oversees DOH and is responsible for all agency operations. (Compl. ¶ 10.) 2. BOP and NaphCare The Bureau of Prisons (“BOP”) is responsible for the custody and care of inmates in federal custody. (Id. ¶ 11.) Under 18 U.S.C. § 4042, BOP: (1) manages and regulates all Federal penal and correctional institutions; (2) provides suitable quarters, safekeeping, care, and subsistence for all persons charged with or convicted of offenses against the United States or held as witnesses; and (3) protects, instructs, and disciplines all persons charged with or convicted of offenses against

1 For the purposes of considering the instant motion, the Court accepts all factual allegations in the Complaint as true. See Phillips v. Cnty. of Allegheny, 515 F.3d 224, 228 (3d Cir. 2008). the United States. (Id.) Pursuant to 18 U.S.C. § 4042, BOP is required to supervise inmates undergoing medical care at an external medical facility in accordance with rights afforded to such inmates under the Fifth and Eighth Amendments to the United States Constitution. (Id. ¶ 15.) BOP has broad authority to enter into contracts with independent contractors to provide medical care that BOP cannot provide in its own facilities. (Id. ¶ 13.) NaphCare, Inc.

(“NaphCare”), a federal contractor, entered into an agreement with BOP to act as its third-party administrator of medical services for federal inmates under BOP supervision. (Id. ¶ 17.) NaphCare is the largest third-party administrator for BOP, and contracts with 47 states to provide post-acute care to BOP inmate patients. (Id. ¶¶ 18–19.) 3. The Sinai-NaphCare Contract On or around June 18, 2024, NaphCare and Sinai entered into an agreement (the “Contract”) wherein Sinai agreed to provide post-acute and rehabilitative care for federal inmates. (Id. ¶ 22.) Shortly thereafter, NaphCare and BOP transferred 11 inmate patients from Metropolitan Detention Center Brooklyn (“MDC Brooklyn”) to Sinai so that they may receive post-acute and rehabilitative care. (Id. ¶ 24.) During the relevant time period Sinai provided in-patient, skilled

nursing care to approximately 390 non-inmate patients, the inmate patients constituted less than three percent of Sinai’s total patient population. (Id. ¶¶ 26–27.) Pursuant to the terms of the Contract, Sinai was required to adhere to the following conditions: • Maintain confidentiality of patient records; • Register inmate patients as “confidential”; • Limit discussions and interactions with the inmate patient to “the consult or treatment being performed for the benefit of the BOP inmate patient”; and • Restrict all patient medical information to authorized individuals. (Id. ¶ 23.) Sinai was not required, nor did it bill or receive any funds or payments from Medicare or Medicaid in connection with the inmate patients. (Id. ¶¶ 25, 32.) 4. DOH’s Investigation and Action at Sinai DOH contacted Sinai almost immediately after the federal inmate patients arrived at the

facility. (Id. ¶ 28.) On July 3, 2024, DOH supervisor Christine Farfalla requested the names of the inmate patients and forwarded a 2016 Department of Health and Human Services, Centers for Medicare and Medicaid Services (“CMS”) memorandum titled, “Guidance to Surveyors on Federal Requirements for Providing Services to Justice Involved Individuals” (the “CMS Memo”). (Id. ¶ 29.) The CMS Memo states that “BOP is responsible for the payment of medical services being provided to patients [in BOP custody].” (Id. ¶ 34.) The CMS Memo provides SNF-specific guidance. (Id. ¶ 35.) Specifically, the CMS Memo notes that: SNFs . . . as residential environments, must permit residents to have autonomy and choice, to the maximum extent practicable regarding how they wish to live their everyday lives and receive care. . . . Facilities cannot require prospective residents to give up their rights as a requirement for admission[.]

(Id.) (emphasis in original.) The CMS Memo also discusses provisions applicable in other care settings, like hospitals and nursing homes. (Id. ¶¶ 35–36.) As to hospitals, the CMS Memo explains: A justice involved individual who has been brought to the hospital . . . and who simultaneously remains in the custody of the [Department of Corrections] or law enforcement personnel, may be subject to security measures imposed by such personnel, such as physical restraint. In order to maintain custody of the individual, the [Department of Corrections]/law enforcement personnel must be physically present with the individual at all times. When enforcement personnel impose security measures, such as the use of restraint, those security measures are not governed by the [Conditions of Participation], as long as the hospital does not participate in such measures. . . . The use of handcuffs, manacles, shackles, other chain-type restraint devices, or other restrictive devices applied by non-hospital employed or contracted law enforcement officials for custody, detention, and public safety reasons are not governed by this rule. The use of such devices are considered law enforcement restraint devices and would not be considered safe, appropriate health care restraint interventions for use by hospital staff to restrain patients. The law enforcement officers who maintain custody and direct supervision of their prisoner (the hospital’s patient) are responsible for the use, application, and monitoring of these restrictive devices in accordance with Federal and State law.

(Id.

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SINAI CENTER FOR REHABILITATION AND HEALTHCARE, LLC v. NEW JERSEY DEPARTMENT OF HEALTH, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sinai-center-for-rehabilitation-and-healthcare-llc-v-new-jersey-njd-2025.