Commonwealth v. Sexton
566 S.W.3d 185
| Mo. Ct. App. | 2018Background
- Medicaid beneficiary Lettie Sexton was hospitalized at Appalachian Regional Healthcare (ARH); Coventry (an MCO) denied reimbursement for 15 additional observation hours after initially approving 23 hours.
- ARH, as Sexton’s designated representative, pursued internal review and then requested a Medicaid Fair Hearing; the hearing officer and Cabinet concluded Sexton lacked standing because Medicaid/ARH bore the financial responsibility.
- ARH filed for judicial review under KRS 13B.140 in Harlan Circuit Court; the circuit court denied motions to dismiss by the Cabinet and Coventry (including sovereign immunity and standing challenges).
- Cabinet and Coventry took interlocutory appeals on sovereign-immunity grounds; the Court of Appeals affirmed waiver of immunity but ordered potential transfer for venue defects; parties sought discretionary review.
- The Kentucky Supreme Court framed the central legal question as whether Kentucky courts require constitutional standing (adopting Lujan) and whether courts must raise standing sua sponte even on interlocutory appeal; it ultimately found Sexton lacked constitutional standing and dismissed the case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Kentucky courts must apply a constitutional standing requirement | Sexton argued she could seek review of Coventry’s denial via her representative; implied statutory process created a right to adjudication | Cabinet/Coventry argued Sexton had no concrete injury and thus no Article III–style standing to sue in state court | Kentucky adopts Lujan test (injury, causation, redressability) as constitutional requirement for state courts; standing is required and not waivable |
| Whether courts may raise standing sua sponte on interlocutory appeal | Sexton/ARH implicitly relied on trial court ruling; argued procedural posture precluded new jurisdictional inquiry | Defendants contended courts must enforce constitutional limits even if not raised | Court held all Kentucky courts must ascertain constitutional standing on their own motion, even on interlocutory appeals properly before the court |
| Whether Sexton suffered an injury-in-fact | Sexton claimed denial of coverage/medical treatment constituted injury | Defendants stressed Medicaid/ARH paid or provided care and statutory scheme prevented personal financial exposure, so Sexton has no concrete, particularized harm | Court held Sexton lacked a concrete, particularized injury—charitable provision of care and Medicaid payment meant no injury-in-fact |
| Whether statutory or procedural rights (Medicaid hearing) confer standing | Sexton argued statutory fair-hearing/process rights create standing to challenge MCO conduct | Defendants argued statutory/process rights do not supplant constitutional standing; procedural violation without concrete injury is insufficient | Court held statutes cannot confer constitutional standing; a bare procedural right without concrete harm is insufficient |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (establishing injury, causation, redressability test for constitutional standing)
- Baker v. Fields, 543 S.W.3d 575 (Ky. 2018) (limits on interlocutory appellate review of immunity issues)
- Breathitt County Bd. of Educ. v. Prater, 292 S.W.3d 883 (Ky. 2009) (framework on narrow use of interlocutory appeals)
- Lawson v. Office of Atty. Gen., 415 S.W.3d 59 (Ky. 2013) (discussion of justiciable causes and standing under Ky. Const.)
- Adarand Constructors, Inc. v. Mineta, 534 U.S. 103 (courts may raise standing sua sponte)
- Spokeo, Inc. v. Robins, 136 S.Ct. 1540 (procedural violations alone insufficient to satisfy injury-in-fact requirement)