NB Ex Rel. Peacock v. District of Columbia, 682 F.3d 77

Five Medicaid recipients sue the District of Columbia in a class action alleging systemic failure to provide timely, written notice for prescription coverage denials as required by federal and D.C. law.
DHCF administers Medicaid in DC and utilizes a prior authorization system; ACS processes electronic claims and provides automatic denial codes.
Plaintiffs claim lack of notice prevents timely remedy or appeal, forcing out-of-pocket payments or delayed access to medications.
District court dismissed for lack of standing; plaintiffs argued procedural rights can support standing when they protect a concrete interest.
Court reviews standing de novo and finds Doe has imminent, ongoing injury from denied coverage and lack of notice, sufficient for injunctive/declaratory relief; remand for proceedings on others' standing as needed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do Doe and the other plaintiffs have Article III standing to seek injunctive and declaratory relief?	Doe alleges ongoing need for prescription coverage and procedural injuries due to missing notices.	District contends past denials and fixes negate ongoing or imminent injury; lack of standing.	Doe has standing to pursue injunctive/declaratory relief at this stage.
Is there an imminent or ongoing injury sufficient for standing where future harms are contingent on agency notice failures?	Procedural violations threaten Doe’s ability to receive benefits and obtain remedies; past injuries show ongoing risk.	Future denials could be justified; no certainty of ongoing injury.	Yes; Doe demonstrates imminent threat of future injury and likelihood of ongoing procedural harm.
Are the injuries traceable to DHCF's failure to provide required notices and redressable by a favorable ruling?	Injury stems from lack of notice enabling remedy, caused by DHCF's procedures.	Injuries attributed to physicians or plan limitations, not DHCF's notices.	Injuries are traceable to DHCF's notice deficiencies and redressable by relief requiring notice.
Should the court decide standing for all plaintiffs or remand to consider others' standing?	Doe's standing suffices to proceed; others may have similar injuries.	Standing for others undetermined; do not decide more than necessary.	Court reverses for Doe's standing; remands for further proceedings on remaining plaintiffs.

Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (three standing elements; procedural rights may relax redressability when protective statutes apply to concrete interests)
City of Los Angeles v. Lyons, 461 U.S. 95 (1983) (live and immediate threat required for standing in injunctive relief)
Center for Law & Educ. v. Dep’t of Educ., 396 F.3d 1152 (D.C. Cir. 2005) (procedural rights can protect concrete interests; relaxed imminence/redressability in such cases)
Sugar Cane Growers Coop. of Fla. v. Veneman, 289 F.3d 89 (D.C. Cir. 2002) (relaxed redressability standard in procedural-rights cases)
Comcast Corp. v. FCC, 579 F.3d 1 (D.C. Cir. 2009) (standing analysis guided by concrete injury and likelihood of future injury)