Justia U.S. 11th Circuit Court of Appeals Opinion SummariesArticles Posted in Health Law
Baker County Medical Services v. U.S. Attorney General, et al.
The Hospital filed suit against various federal agencies and officials, seeking a declaratory judgment that 18 U.S.C. 4006(b)(1), where Congress has elected to impose the Medicare rate as full compensation for medical services rendered to federal detainees, is unconstitutional as applied. The court concluded that the Hospital voluntarily opted into the Medicare program and is, as a result, required to provide emergency services to federal detainees. Consequently, the Hospital was foreclosed from challenging this compensation scheme as an unconstitutional taking under the Fifth Amendment. The court noted that the Hospital's most effective remedy may lie with Congress rather than the courts. Accordingly, the court affirmed the district court's dismissal of the action.View "Baker County Medical Services v. U.S. Attorney General, et al." on Justia Law
Wollschlaeger, et al. v. Governor State of FL, et al.
The State appealed the district court's grant of summary judgment and an injunction in favor of plaintiffs, enjoining enforcement of Florida's Firearm Owners Privacy Act, Fla. Stat. 381.026, 456.072, 790.338, on First and Fourteenth Amendment grounds. The Act seeks to protect patients' privacy by restricting irrelevant inquiry and record-keeping by physicians regarding firearms. The court concluded that plaintiffs have standing to challenge the Act and plaintiffs' claims are ripe for adjudication; the Act is a legitimate regulation of professional conduct where the Act simply codifies that good medical care does not require inquiry or record-keeping regarding firearms when unnecessary to a patient's care, and any burden the Act places on physician speech is incidental; and the Act is not unconstitutionally vague when the Act is properly understood as a regulation of physician conduct intended to protect patient privacy and curtail abuses of the physician-patient relationship, and it is readily apparent from the language of the Act the type of conduct the Act prohibits. Accordyingly, the court reversed the district court's grant of summary judgment and vacated the injunction.View "Wollschlaeger, et al. v. Governor State of FL, et al." on Justia Law
Jim Walter Resources, Inc. v. Director, OWCP, et al.
Petitioner sought review of a decision awarding benefits to a miner's widow under the Black Lung Benefits Act, 30 U.S.C. 901 et seq. The court found, after reviewing petitioner's arguments and the relevant law, that nothing precludes a new benefits claim by a survivor whose previous application was denied under the pre-Affordable Care Act (ACA), Pub. L. No. 111-148, section 1556, 124 Stat. 119, 260, version of the Black Lung Benefits Act. Thus, the court held that a survivor who filed a claim before January 1, 2005 may submit a new claim that must be adjudicated under the post-ACA statutory provisions. The court denied the petition for review and affirmed the award of benefits. View "Jim Walter Resources, Inc. v. Director, OWCP, et al." on Justia Law
Posted in: Health Law
Garrido, et al. v. Interim Secretary, FL Agency for Health Care Admin.
Plaintiffs filed suit against defendant, in her official capacity as Interim Secretary for the Florida Agency for Health Care Administration (AHCA), alleging that defendant violated the Medicaid Act, 42 U.S.C. 1396 et seq., by denying Medicaid coverage of applied behavioral analysis (ABA) to treat plaintiffs' autism spectrum disorders. The court concluded that the district court did not abuse its discretion in issuing a permanent injunction that overruled AHCA's determination that ABA was experimental and required Medicaid coverage of this treatment. However, because the language in the injunction's final sections was out of step with the district court's analysis and what was actually decided, the court vacated the injunction in part and remanded to the district court to modify Paragraphs 2 and 6. View "Garrido, et al. v. Interim Secretary, FL Agency for Health Care Admin." on Justia Law
U.S. Steel Mining Co., LLC v. Director, OWCP, et al.
U.S. Steel appealed the award of benefits to plaintiff, the widow of a deceased miner, under the black lung benefits program. The Benefits Review Board affirmed the award, concluding that plaintiff did not need to show the cause of her husband's death. The court concluded that 30 U.S.C. 932(l), as amended by section 1556(b) of the Patient Protection and Affordable Care Act, Pub. L. No. 111-148, 1556(b), 124 Stat. 119, 260, eliminated the need for survivors who could meet its requirements to prove that their associated miners died due to black lung disease; it applied retroactively to survivors' claims filed in the specified period; and this retroactive application did not violate the Due Process Clause of the Fifth Amendment. Accordingly, the court denied U.S. Steel's petition to review the Board's ruling. View "U.S. Steel Mining Co., LLC v. Director, OWCP, et al." on Justia Law
OPIS Mgmt. Res. LLC, et al v. Sec., FL Agency for Health Care Admin.
This case stemmed from requests to the Nursing Facilities from spouses and attorneys-in-fact for medical records of deceased nursing home residents. At issue was whether section 400.145 of the Florida Statutes was preempted by the Federal Health Insurance Portability and Accountability Act of 1996 (HIPAA), 42 U.S.C. 1320d to d-9, and its implementing regulations. The court held that section 400.145 and HIPAA could not be reconciled and the court agreed with the district court that the Florida statute stood as an obstacle to the accomplishment and execution of the full purposes and objectives of HIPAA in keeping an individual's protected health information strictly confidential. Accordingly, the court affirmed the district court's judgment that the Florida statute was preempted and its grant of summary judgment in favor of the Nursing Facilities, explaining that the Florida statue afforded nursing home residents less protection than was required by the federal law. View "OPIS Mgmt. Res. LLC, et al v. Sec., FL Agency for Health Care Admin." on Justia Law
Fresenius Medical Care Holding, et al v.Tucker, et al
Plaintiffs challenged Florida's "Patient Self-Referral Act of 1992" (the Florida Act), Fla. Stat. 456.053, which prohibited Florida physicians from referring their patients for services to business entities in which the referring physicians have a financial interest. The court concluded that the conflict preemption doctrine did not apply, and the exemptions in federal law allowing physicians serving end-stage renal disease patients to engage in self-referral did not preempt Florida's more restrict law prohibiting such conduct. The court also concluded that the Florida Act did not discriminate against interstate commerce, nor did it impose a burden on interstate commerce that was clearly excessive when compared with the law's putative local benefits. Therefore, the Florida Act did not violate the dormant Commerce Clause. Further, plaintiffs' substantive due process claim failed to survive rational basis scrutiny, and an equal protection claim would fail as well. Accordingly, the court affirmed the judgment. View "Fresenius Medical Care Holding, et al v.Tucker, et al" on Justia Law
Martes, et al. v. CEO of South Broward Hospital Dist., et al.
Plaintiffs appealed from the district court's dismissal of their amended complaint against Florida government defendants, SBHD, AHCA, and DCF. Plaintiffs alleged that defendants' billing practice violated both 42 U.S.C. 1396a(a)(25)(C), the "balance billing" provision of the federal Medicaid Act, and a similar Florida statute. The court concluded that section 1396a(a)(25)(C) did not confer upon plaintiffs a federal right enforceable under 42 U.S.C. 1983 and therefore, affirmed the district court's decision to dismiss the amended complaint. View "Martes, et al. v. CEO of South Broward Hospital Dist., et al." on Justia Law
Maradiaga, et al. v. United States
Plaintiffs, on behalf of themselves and their child, appealed the dismissal of their complaint against the United States and the denial of their motions for relief from judgment and to reopen the case. The primary issue on appeal was whether the United States was amendable to suit under the Federal Tort Claims Act (FTCA), 28 U.S.C. 1346(b), 2401(b), 2671-80, for the negligence of medical professionals employed by a federally supported health center when like private professionals would be immune from suit under the Florida Birth-Related Neurological Injury Compensation Act, Fla. Stat. 766.301-16. The United States claimed that the Compensation Act could not expand the liability of the United States under the FTCA beyond that to which an analogous private party would be amenable and that plaintiffs have waived any right to have the district court abate their action pending the determination by the ALJ. Because the court agreed with the United States, the court affirmed the dismissal of plaintiffs' complaint and the denial of their motions for relief from judgment and to reopen the case. View "Maradiaga, et al. v. United States" on Justia Law
State of Alabama v. Centers For Medicare And Medicaid, et al.
Alabama sued CMS claiming that it violated the federal Administrative Procedures Act (APA), 5 U.S.C. 500-596, 701-706, by issuing - without notice and an opportunity for public comment - an October 28, 2008 letter to state health officials (SHO letter). The district court held that the SHO letter constituted a substantive administrative rule issued without the notice-and-comment procedures mandated by the APA. Because the district court did not abuse its discretion in denying injunctive relief in addition to vacating the SHO letter, and because Alabama's remaining claims were unripe, the district court's judgment was affirmed. View "State of Alabama v. Centers For Medicare And Medicaid, et al." on Justia Law