Bruns v. Mayhew
931 F. Supp. 2d 260
D. Me.2013Background
- Maine provided Medicaid (MaineCare) to residents, including some noncitizens, until 2011 when a new law ended coverage for Medicaid-ineligible aliens.
- PRWORA created two groups for eligibility: qualified aliens and non-qualified aliens, with a five-year residency rule for federal benefits and emergency care allowed.
- In 1997 Maine enacted state-funded health benefits for Medicaid-ineligible qualified aliens under TANF; this program operated separately from MaineCare.
- In 2011 Maine enacted Public Law 2011, ch. 380, KK-4 to terminate the aliens-only health benefit program; DHHS implemented it by emergency rule.
- Bruns (lawful permanent resident) and Hassan (asylum-seeker) sued claiming equal protection violation and asked for a preliminary injunction to restore benefits; court denied relief finding no likelihood of success on the merits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Equal protection violation from aliens-only termination | Bruns argues alienage-based classification violates EP. | Maine created two separate programs post-PRWORA, not a single group; no selective treatment. | Denied; two separate programs negate ‘similarly situated’ comparison. |
| Existence of two separate benefit programs post-PRWORA | Plaintiffs contend MaineCare and aliens-only program are one coverages. | There are two distinct programs funded and controlled separately. | Confirmed; programs are distinct, undermining EP claim. |
| Irreparable harm shown without injunction | Plaintiffs suffer ongoing, non-compensable medical harm. | Emergency care and Free Care options exist; record is undeveloped. | Not satisfied; record insufficient and likelihood of success lacking. |
| Balance of hardships and public interest | State savings are minor; harms to plaintiffs outweigh. | Budgetary concerns and public interest in solvency favor restraint. | Neutral on public interest; no injunction due to lack of likelihood of success. |
Key Cases Cited
- Graham v. Richardson, 403 U.S. 365 (1971) (equal protection requires similar treatment for similarly situated individuals)
- City of Cleburne v. Cleburne Living Ctr., 473 U.S. 432 (1985) (how to determine similarly situated and scrutiny level)
- Barrington Cove, Ltd. v. R.I. Hous. & Mortg. Fin. Corp., 246 F.3d 1 (1st Cir. 2001) (two-step test for similarly situated; not always exact correlation)