Falsetto v. Health Net Access Incorporated
3:25-cv-08170
D. Ariz.Aug 22, 2025Background
- Plaintiff Nicholas D. Falsetto, who has multiple disabilities and an SMI (Serious Mental Illness) designation, filed suit alleging denial of coordinated, timely, and medically necessary services by Arizona Complete Health and affiliated defendants.
- Falsetto sought to proceed in forma pauperis, alleging violations under the Americans with Disabilities Act (ADA) and Rehabilitation Act related to failures in providing services and supports, supposedly due to his disabilities.
- The complaint named Health Net Access Inc. (Arizona Complete Health), its parent company Centene Corporation, and individual employees Copeland Peeples Cahill (case manager) and Danyale M. Schmidt (SMI Supervisor).
- The complaint sought $37 million in damages and injunctive relief requiring provision of ADA-compliant services.
- The court granted the motion to proceed in forma pauperis but dismissed the complaint for lack of sufficient factual detail, giving leave to amend and setting a deadline for amendment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of ADA/Rehabilitation Act pleading | Services denied due to disability, requiring relief | Not specified; ruled on sufficiency of facts | Complaint too vague, lacks necessary detail |
| Specificity of allegations against defendants | Defendants' conduct caused harm based on disability | Not specified; ruled on pleading deficiency | Must identify who did what, when, and why |
| Right to proceed in forma pauperis | Unable to pay filing fee, entitled to relief | Not opposed | Granted |
| Proper basis for injunctive and monetary relief | Denied necessary medical/mental health services | Not addressed | Dismissed for lack of plausible supporting facts |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaints must have factual content to show plausible entitlement to relief)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleadings must cross from conceivable to plausible)
- Mann v. City of Tucson, Dep't of Police, 782 F.2d 790 (9th Cir. 1986) (vague and conclusory allegations are insufficient)
- McHenry v. Renne, 84 F.3d 1172 (9th Cir. 1996) (plaintiffs must state who is being sued, for what relief, and what theory)