Doe v. Kidd
419 F. App'x 411
4th Cir.2011Background
- Doe, a disabled young woman, sues SC DDSN and DHHS and certain state officials under §1983 for Medicaid Act violations.
- Prior Fourth Circuit Doe I decision affirmed in part and remanded; issue surviving was timely provision of services.
- District court granted summary judgment for defendants on Doe’s reasonable promptness claim in 2010, denying relief.
- Doe sought attorney’s fees and, separately, a motion to amend the complaint; the latter was denied.
- Appellate court reverses in part, holds defendants violated the Medicaid Act by not providing residential habilitation in a proper setting with reasonable promptness, and remands for remedial relief and fees.
- District court is instructed to grant summary judgment in Doe’s favor on the merits and determine fees; denial of amendment affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of services under Medicaid Act | Doe argued defendants failed to provide 2003 plan services promptly | Defendants argued they funded other services and were not required to provide specific residential habilitation | Defendants violated the Medicaid Act; timely provision required |
| Prevailing party status and fees | Doe sought fees as prevailing party after reversal on merits | Defendants contended no prevailing party due to partial relief | Doe is prevailing party; entitled to reasonable attorney’s fees |
| Leave to amend | Doe's amendments sought to raise constitutional claims tied to state proceedings | Amendment would be futile and untimely | District court did not abuse discretion in denying amendment |
Key Cases Cited
- Doe I, Doe v. Kidd, 501 F.3d 348, 501 F.3d 348 (4th Cir. 2007) (affirms in part, reverses in part on Medicaid promptness issue; right to choose setting and providers under waiver program)
- Wilder v. Va. Hosp. Ass’n, 496 U.S. 498 (U.S.) (Medicaid funding bound to comply with federal laws)
- Bruggeman ex rel. Bruggeman v. Blagojevich, 324 F.3d 906 (7th Cir. 2003) (debates scope of 'medical assistance' vs funding; relevance to timely provision of funds)
- Silver v. Baggiano, 804 F.2d 1211 (11th Cir. 1986) (right to choose provider under Medicaid 1396a(a)(23))
- Alexander v. Hill, 707 F.2d 780 (4th Cir. 1983) (district courts may fashion equitable remedies for ongoing Medicaid violations)
- Smyth ex rel. Smyth v. Rivero, 282 F.3d 268 (4th Cir. 2002) (fees awarded to prevailing party; standards of review)
- Feldman, Dist. of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (U.S.) (Rooker-Feldman doctrine; limits on federal review of state judgments)
- Farrar v. Hobby, 506 U.S. 103 (U.S.) (prevailing claimant in civil rights action; effect on fee shifting)
- Hanrahan v. Hampton, 446 U.S. 754 (U.S.) (fees available where plaintiff prevails on merits)