938 N.E.2d 823
Ind. Ct. App.2010Background
- FSSA administers Medicaid in Indiana; Hearings and Appeals handle denial appeals for Medicaid disability benefits.
- IBM/ACS modernization made telephonic hearings common in modernized counties; ACS represented state at eligibility stage during hearings.
- Since Jan 7, 2009, Medicaid disability appeals began telephonically in modernized counties; in-person hearings remained available upon request.
- Notices informed applicants they could request in-person hearings; in-person hearings required travel of ALJ and State to the applicant's county.
- As of Oct 1, 2009, FSSA shifted to hybrid hearings (in-person with telephonic State participation) and updated notices accordingly.
- Class action defined: Medicaid disability applicants/recipients denied MA D who appealed, with two sub-classes based on notice form; trial court granted summary judgment for the Class; State appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether unsuccessful Medicaid disability applicants have a constitutional right to an in-person hearing. | Terrell argues yes; due process requires in-person hearing. | Murphy/Casanova argue telephonic or hybrid hearings satisfy due process. | No constitutional right to in-person hearing; telephonic/hearing safeguards suffice; reversed for State summary judgment. |
Key Cases Cited
- Goldberg v. Kelly, 397 U.S. 254 (U.S. 1970) (due process requires meaningful opportunity to be heard and tailored procedures)
- Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (three-factor due process balancing test for notice and hearing)
- State ex rel. Human Servs. Dept. v. Gomez, 657 P.2d 117 (N.M. 1982) (telephonic hearings can pass constitutional muster; demeanor not essential)