United States v. Elderwood Health Care at Linwood

CourtDistrict Court, W.D. New York
DecidedJuly 15, 2025
Docket1:15-cv-00099
StatusUnknown

This text of United States v. Elderwood Health Care at Linwood (United States v. Elderwood Health Care at Linwood) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Elderwood Health Care at Linwood, (W.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

JEAN NOLAN,

Plaintiff,

v. DECISION AND ORDER 15-CV-99S

POST ACUTE PARTNERS MANAGEMENT, LLC, 1818 COMO PARK BOULEVARD OPERATING CO., LLC, and ELDERWOOD ADMINISTRATIVE SERVICES, LLC,

Defendants.

I. INTRODUCTION In this action, Plaintiff Jean Nolan alleges that Defendants illegally retaliated against her for reporting fraudulent health insurance-related practices that subsequently gave rise to claims under the federal False Claims Act, 31 U.S.C. §§ 3729 et seq., as amended (“the FCA”), and the New York False Claims Act, N.Y. Fin. L. §§ 187-194 (“the NY FCA”). Nolan asserts retaliation claims under 31 U.S.C. § 3730 (h) and N.Y. Fin. L. § 191 in a second amended complaint. (Docket No. 66.) Pending before this Court is Defendants’ motion to dismiss the second amended complaint.1 (Docket No. 86.) For the reasons set forth below, the motion is granted in part and denied in part.

1 In support of their motion, Defendants filed a notice of motion, a declaration with exhibit, and a memorandum of law. (Docket No. 86 and subparts.) Nolan filed a memorandum of law in opposition, a declaration with exhibits, and a second declaration. (Docket No. 93 and subparts.) In reply, Defendants filed a memorandum of law and two declarations, each with exhibits. (Docket No. 94 and subparts) This Court took the motion under advisement without oral argument. II. BACKGROUND This Court assumes the truth of the factual allegations contained in the second amended complaint. See Hosp. Bldg. Co. v. Trs. of Rex Hosp., 425 U.S. 738, 740, 96 S. Ct. 1848, 48 L. Ed. 2d 338 (1976); see also Hamilton Chapter of Alpha Delta Phi, Inc. v.

Hamilton Coll., 128 F.3d 59, 63 (2d Cir. 1997). Defendant Post Acute Partners Management, LLC (“PAPM”), is a privately held company that owns and operates facilities in several states that provide post-acute healthcare services, including skilled nursing and inpatient rehabilitation. See Second Amended Complaint (“SAC”), Docket No. 66, ¶ 12. Defendant Elderwood Administrative Services, LLC (“EAS”), is a health care management firm that has provided skilled nursing in New York since 1978. Id. ¶ 13. It owns and operates 17 rehabilitation, skilled nursing, assisted living, and independent living communities in Western New York, including a facility located at 1818 Como Park Boulevard in Lancaster, N.Y. Id. PAPM acquired EAS in 2013. Id. ¶ 13.

Defendant 1818 Como Park Boulevard Operating Co., LLC (“1818 Como Park”), appears to operate EAS’s facility located at 1818 Como Park Boulevard in Lancaster, which this Court will refer to as Elderwood Lancaster. Id. ¶¶ 4, 14. Nolan is an experienced licensed practical nurse. Id. ¶ 38. Over the course of her long career, she worked in multiple facilities and acquired knowledge of state and federal regulations that govern the skilled-nursing and long-term-care industries. Id. In April 2013, Nolan began working the night shift at Elderwood Lancaster on a per diem basis. Id. Two weeks later, she transitioned to working there full-time. Id. Throughout the course of her employment, Nolan personally observed numerous unlawful and fraudulent practices intended to maximize payments from federally and state funded health insurance programs—Medicare, Medicaid, and TRICARE. See, e.g., id. ¶¶ 4-9, 8A2, 39. These practices are detailed in the second amended complaint, but are not at issue on this motion. Id. ¶¶ 42-61 (detailing fraudulent practices involving patient

admissions in rehabilitation programs), 62-88 (detailing fraudulent practices involving manipulation of requirements to treat patients for whom services were not medically reasonable or necessary), 89-95 (detailing fraudulent billing of skilled nursing services to inflate billings). Nolan refused to engage in these practices and complained about them to her supervisors and to the corporate office, beginning in October 2013. Id. ¶¶ 9A, 10, 40, 96-116. What followed, according to Nolan, was a course of illegal retaliation. Id. ¶¶ 10, 96-116. Nolan was first treated with hostility and threatened. Id. ¶¶ 10, 98. Then, when Nolan continued to speak out against the illegal practices, Defendants changed her position, so that she could no longer observe and report the offending conduct. Id. ¶ 10.

And when Nolan reported the conduct to upper management, her supervisors created a pretext for her termination and ultimately terminated her employment at the end of April 2014.3 Id. ¶¶ 10, 115. Nolan maintains that the retaliation and termination violate the anti-retaliation provisions in the federal and state False Claims Acts, specifically, 31 U.S.C. § 3730 (h) and N.Y. Fin. L. § 191. Id. ¶¶ 117-124. These two claims are the only ones remaining in this matter.

2 Two paragraphs in the second amended complaint are misnumbered. At the top of page 5, paragraph numbers 8 and 9 are mistakenly repeated. For the sake of clarity, this Court will refer to those two paragraphs as 8A and 9A.

3 Nolan’s termination date is unclear in the second amended complaint. In paragraph 10, she alleges that she was terminated on April 29, 2014. SAC, ¶ 10. In paragraph 115, she alleges that she was terminated four days earlier, on April 25, 2014. Id. ¶ 115. Defendants’ motion implicates the relation-back doctrine, specifically whether Nolan’s second amended complaint relates back to her original complaint, which did not name any of the present defendants. See Fed. R. Civ. P. 15 (c). Examination of the past named parties is therefore required.

Nolan originally commenced this action as a qui tam suit more than a decade ago, on behalf of herself, the United States, and the State of New York. She filed the initial complaint on February 3, 2015, and named as defendants Elderwood Health Care at Linwood; Elderwood Senior Care, Inc.; Post Acute Partners; and Does 1-100. (Docket No. 1.) Nolan thereafter filed a first amended complaint on October 7, 2016, which dropped Elderwood Health Care at Linwood as a defendant, but kept in Post Acute Partners, Elderwood Senior Care, Inc., and Does 1-100. (Docket No. 16.) On July 29, 2022, the United States and the State of New York filed a Notice of Intervention in part and Declination in part for purposes of effectuating partial settlement. (Docket No. 59.) But the partial settlement, and the subsequent joint stipulation of

dismissal (Docket No. 62), did not involve any of the entities named in the first amendment complaint, which was the operative pleading at the time. Instead, they named and involved entities that had not yet been sued in this action, including 1818 Como Park Boulevard Operating Co., LLC, and Elderwood Administrative Services, LLC, both of whom Nolan later named in the second amended complaint. Following the partial settlement, on December 22, 2022, Plaintiff and Post Acute Partners stipulated to limited amendment of the first amended complaint to include only the removal of claims brought on behalf of the United States or the State of New York and the addition of details concerning Nolan’s retaliation allegations. (Docket Nos. 63, 64.) On January 18, 2023, Plaintiff filed the second amended complaint now at issue. Again, it names as defendants Post-Acute Partners Management, LLC; 1818 Como Park

Boulevard Operating Co., LLC; and Elderwood Administrative Services, LLC.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Hospital Building Co. v. Trustees of Rex Hospital
425 U.S. 738 (Supreme Court, 1976)
Baldwin County Welcome Center v. Brown
466 U.S. 147 (Supreme Court, 1984)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
KRUPSKI v. COSTA CROCIERE S. P. A
560 U.S. 538 (Supreme Court, 2010)
Advanced Magnetics, Inc. v. Bayfront Partners, Inc.
106 F.3d 11 (Second Circuit, 1997)
Faulkner v. Beer
463 F.3d 130 (Second Circuit, 2006)
Meilleur v. Strong
682 F.3d 56 (Second Circuit, 2012)
Zapata v. City of New York
502 F.3d 192 (Second Circuit, 2007)
ATSI Communications, Inc. v. Shaar Fund, Ltd.
493 F.3d 87 (Second Circuit, 2007)
TADCO Construction Corp. v. Dormitory Authority
700 F. Supp. 2d 253 (E.D. New York, 2010)
McKenna Ex Rel. United States v. Senior Life Management, Inc.
429 F. Supp. 2d 695 (S.D. New York, 2006)
Hogan v. Fischer
738 F.3d 509 (Second Circuit, 2013)
Town of Hempstead v. Lizza Industries, Inc.
293 A.D.2d 739 (Appellate Division of the Supreme Court of New York, 2002)
Harris v. City of New York
186 F.3d 243 (Second Circuit, 1999)
Chambers v. Time Warner, Inc.
282 F.3d 147 (Second Circuit, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Elderwood Health Care at Linwood, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-elderwood-health-care-at-linwood-nywd-2025.