In re The Estate of Michael Patrick Smith v. Heckler case brief

In re The Estate of Michael Patrick Smith v. Heckler case brief summary
747 F.2d 583 (1984)

CASE SYNOPSIS

Plaintiffs, class of Medicaid recipients, sought relief under 42 U.S.C.S. § 1983 and brought a class action against defendants, Secretary of Health and Human Services (Secretary), various public officials, and nursing home operators. The United States District Court for the District of Colorado denied relief. The class of Medicaid recipients appealed.

CASE FACTS
On appeal, the class of Medicaid recipients alleged that the Secretary had a statutory duty under Title XIX of the Social Security Act (act), 42 U.S.C.S. §§ 1396-1396, commonly known as the Medicaid Act, to develop and implement a system of nursing home review and enforcement designed to ensure that Medicaid recipients residing in Medicaid certified nursing homes actually receive the optimal medical and psychosocial care that they were entitled to under the act.

DISCUSSION

• The court reversed and remanded the case. 
• In so doing, the court held that 
• (1) the trial court erred in finding that the Secretary did not have a statutory duty to develop and implement a system of nursing home review and enforcement that focuses on and ensures high quality patient care, 
• (2) the enforcement mechanism promulgated by the Secretary had not satisfied that duty, and 
• (3) mandamus was an appropriate remedy to compel performance.

CONCLUSION
The judgment was reversed and remanded.

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