Thursday, November 14, 2013

Blum v. Yaretsky case brief

Blum v. Yaretsky case brief summary
457 U.S. 991 (1982)

The United States Court of Appeals for the Second Circuit affirmed a district court's judgment in favor of respondent patients. The patients received assistance under the Medicaid program established by Title XIX of the Social Security Act, 42 U.S.C.S. § 1496 et seq. Petitioners, state social service officials, appealed the holding that there was state action and a constitutional right to a pre-transfer evidentiary hearing in a patient transfer.

A nursing home's utilization review committee sought to transfer respondent patients to a lower level of care. The state social service officials affirmed the decision to discontinue benefits unless the patients accepted a transfer. The patients filed a lawsuit against the officials, seeking injunctive relief and damages. The district court approved a consent judgment and issued a permanent injunction against the officials. The circuit court affirmed.

  • After granting certiorari, the Court concluded that the patients had standing because of the threat of facility-initiated discharges or transfers to lower levels of care was sufficiently substantial. 
  • However, the Court held that the district court exceeded its authority in adjudicating the procedures governing transfers to higher levels of care because none of the patients had been threatened with such transfers. 
  • The Court further held that the patients failed to establish state action in the nursing homes' decisions. 
  • The Court determined that the state's form completion requirement and its obligation to adjust benefits did not influence decisions made by physicians and nursing home administrators. 
  • The judgment was reversed.

The circuit court's decision affirming the district court's judgment in favor of the patients, based on a finding that there was state action and a constitutional right to a pre-transfer hearing, was reversed.

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