New York Times Profiles Two Recent Court Rulings Allowing Medicaid Beneficiaries To Sue State Officials

Two federal appeals court rulings issued this month that said that low-income individuals may sue state officials to force them to provide federally mandated Medicaid benefits could have a "significant" effect on the program, the New York Times reports. In one case, the 6th U.S. Circuit Court of Appeals in Cincinnati ruled in favor of parents who sued Michigan to provide early and periodic screening, diagnostic and treatment services -- a benefit known as EPSDT, which under federal Medicaid law states must provide to children younger than age 21 -- for their seven-year-old child. The appeals court rejected Michigan officials' claim that federal Medicaid law "is not enforceable" by individual Medicaid beneficiaries. Judge Gilbert Merritt said that "doctrines of sovereign immunity" provide "no shield" for state officials accused of "depriving citizens of a federal right." The decision overturned a ruling issued last May in federal District Court in Detroit.

North Carolina Case
In the North Carolina case, attorneys filed suit against the state on behalf of children who did not receive dental care and other services that states must provide under federal Medicaid law. Judge Paul Niemeyer of the 4th U.S. Circuit Court of Appeals in Richmond, Va., said that North Carolina officials could not use the state's "sovereign immunity shield" to avoid the lawsuit. "A state officer acting in violation of federal law loses the cloak of state immunity," Niemeyer said. The Times reports that both rulings represent "an important victory" for Medicaid beneficiaries (Pear, New York Times, 5/26).