Boyd v. Steckel
753 F. Supp. 2d 1163
M.D. Ala.2010Background
- Boyd, a 34-year-old tetraplegic, sued Alabama Medicaid Commissioner Steckel alleging ADA and Rehabilitation Act violations for failing to provide community-based services.
- Boyd lives in a nursing facility; his community-based waiver services were discontinued when he entered the facility, though he previously received waivers via a caregiver.
- Alabama operates six Medicaid waivers (E&D, ID, LAH, SAIL, HIV/AIDS, TA) with caps and service limitations; SAIL and E&D impose hours and skilled-care limits and have waiting lists.
- Boyd seeks 10 hours/day ADL assistance and other waiver supports to live in the community, attend graduate school, and participate in university life.
- DOJ filed an amicus brief supporting Boyd; the court held an expedited hearing and denied the preliminary injunction, finding no substantial likelihood of success at this stage.
- Key evidentiary disputes center on whether Boyd is qualified for a waiver, the adequacy of Dr. Moon’s medical assessment, cost-effectiveness of community-based services, and the potential fundamental-alteration defense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Boyd is qualified for community-based services under Olmstead | Boyd is eligible for community-based waiver services meeting his needs. | Moon's assessment suggests additional services are required; he may not meet waiver eligibility. | No substantial likelihood of success; qualification not established at this stage. |
| Whether providing community-based services would be more cost-effective than nursing facility care | Waiver costs are substantially lower than nursing-home costs, implying cost-neutrality supports relief. | Costs must be evaluated for Boyd specifically; waiver data reflect average costs, not individual needs. | Not established; record insufficient to prove cost-savings for Boyd. |
| Whether Olmstead's fundamental-alteration defense bars relief | Courts must provide community-based services when appropriate and feasible within resources. | Fundamental alteration allows State to avoid changing the Medicaid structure given overall budget. | No; likelihood of success on fundamental alteration not shown; relief would substantially disrupt the program. |
| Whether granting a preliminary injunction would be appropriate given Olmstead's plurality and state resource considerations | State must expand community-based options when appropriate; waiting lists should not bar relief. | Courts should not leapfrog top-of-waiting-list individuals; broad program disruption and lack of record justification. | Not appropriate; injunction denied to avoid undermining the Medicaid scheme. |
Key Cases Cited
- Olmstead v. L.C. by Zimring, 527 U.S. 581 (U.S. 1999) (integration and reasonable modification framework; community-based placement when appropriate)
- Lambert v. United States, 695 F.2d 536 (11th Cir. 1983) (preliminary injunction standards; status quo preservation)
- Mercedes-Benz U.S. Int'l, Inc. v. Cobasys, LLC, 605 F.Supp.2d 1189 (N.D. Ala. 2009) (preliminary injunction framework; caution against mandatory relief)
- Arc. of Wash. State Inc. v. Braddock, 427 F.3d 615 (9th Cir. 2005) (fundamental-alteration considerations under Olmstead; budget context)
- Pennsylvania Prot. & Advocacy, Inc. v. Pa. Dept. of Pub. Welfare, 402 F.3d 374 (3d Cir. 2005) (budgetary constraints and fundamental alteration; not sole determinant)