Soskin v. Reinertson case brief summary
353 F.3d 1242 (2004)
CASE FACTS
Plaintiffs sought a judgment declaring that eligibility requirements of Sen. Bill 03-176 (Colo. 2003) violated the Equal Protection Clause because they discriminated against legal aliens, and that the Director's procedures for terminating benefits were inadequate under Medicaid and the Due Process Clause. Plaintiffs also sought an injunction permanently enjoining termination of benefits under the Bill. The constitutionality of the Bill depended on the level of scrutiny applied.
DISCUSSION
The court vacated its injunction pending appeal and affirmed the denial of plaintiffs' motion for a preliminary injunction, except that it reversed in part and remanded for entry of a preliminary injunction prohibiting the Director from terminating benefits to any member of the class under certain circumstances related to notice.
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353 F.3d 1242 (2004)
CASE SYNOPSIS
Plaintiffs, a class of legal aliens,
sued defendant, the Executive Director of the Colorado Department of
Health Care Policy and Financing, alleging, inter alia, that a
Colorado law's Medicaid eligibility requirements violated Equal
Protection. The U.S. District Court for the District of Colorado
denied plaintiffs a preliminary injunction. Plaintiffs
appealed.CASE FACTS
Plaintiffs sought a judgment declaring that eligibility requirements of Sen. Bill 03-176 (Colo. 2003) violated the Equal Protection Clause because they discriminated against legal aliens, and that the Director's procedures for terminating benefits were inadequate under Medicaid and the Due Process Clause. Plaintiffs also sought an injunction permanently enjoining termination of benefits under the Bill. The constitutionality of the Bill depended on the level of scrutiny applied.
DISCUSSION
- The court applied rational-basis review to distinctions based on nonsuspect classifications. Having found that the Equal Protection claim lacked merit, the court could hardly find an abuse of discretion in denying injunctive relief.
- Next, the court found that the Director had to grant an opportunity for a hearing to any recipient who requested it because he or she believed the Director had taken an action erroneously.
- No such hearing rights were recognized by the Director for those individuals who failed to return their redetermination forms.
- Thus, the denial of a preliminary injunction requiring that such persons be advised of the right to request a pre-termination hearing was reversed.
The court vacated its injunction pending appeal and affirmed the denial of plaintiffs' motion for a preliminary injunction, except that it reversed in part and remanded for entry of a preliminary injunction prohibiting the Director from terminating benefits to any member of the class under certain circumstances related to notice.
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