Bruns v. Mayhew
750 F.3d 61
1st Cir.2014Background
- Medicaid is a federal-state program; states may participate but must meet federal requirements to receive funds.
- PRWORA in 1996 restricted federal benefits for aliens and created categories of qualified vs non-qualified aliens.
- Maine enacted a 1997 state law to provide state-funded medical care to PRWORA-ineligible aliens; this program operated alongside MaineCare (Medicaid).
- In 2011 Maine repealed the state-funded aliens-only benefits, terminating those coverage for PRWORA-ineligible aliens.
- Plaintiffs Bruns and Hassan represent PRWORA-ineligible aliens in Maine who lost benefits and challenge the 2011 repeal under the Equal Protection Clause.
- District court denied a preliminary injunction; the First Circuit reviews the denial de novo for legal conclusions and with deference to factual findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Maine’s action violated equal protection by alienage-based treatment | Bruns argues aliens were similarly situated to citizens and eligible aliens | Mayhew contends no alienage-based discrimination occurred; benefits were under separate programs | No equal protection violation; two programs were separately administered and not similarly situated. |
| Whether Maine discriminated by treating PRWORA-ineligible aliens differently under MaineCare | Bruns claims PRWORA-ineligible aliens were singled out for termination | State funded aliens-only benefits were a separate program, not a uniform state policy | No discrimination; termination did not deprive a benefit shared with citizens/eligible aliens under a single program. |
| Whether the case should be dismissed for failure to state a claim | Complaint adequately alleged statutory framework and deprivation | Complaint framed as law, not fact; discovery would not salvage a claim | Case dismissed with prejudice; complaints fail to state an equal protection claim. |
Key Cases Cited
- Barrington Cove Ltd. P'ship v. R.I. Hous. & Mortg. Fin. Corp., 246 F.3d 1 (1st Cir. 2001) (disparate treatment requires a similarly situated comparison in equal protection)
- Dartmouth Review v. Dartmouth Coll., 889 F.2d 13 (1st Cir. 1989) (test for whether groups are similarly situated in equal protection)
- Cordi-Allen v. Conlon, 494 F.3d 245 (1st Cir. 2007) (two groups must engage in same activity vis-à-vis government)
- Graham v. Richardson, 403 U.S. 365 (1971) (alienage classifications generally subject to strict scrutiny)
- Mathews v. Díaz, 426 U.S. 67 (1976) (congressional alienage-based restrictions receive rational basis review)
- Plyler v. Doe, 457 U.S. 202 (1982) (federal/state balance on immigration policy; states not have plenary power over aliens)
- Pimentel v. Dreyfus, 670 F.3d 1096 (9th Cir. 2012) (appearance of a single program does not negate two separately funded programs)