Salazar v. Dist. of Columbia
896 F.3d 489
D.C. Cir.2018Background
- Plaintiffs (Medicaid applicants and recipients) brought a 1993 class action against D.C. alleging systemic failures in Medicaid application processing, renewals, and delivery of Early Childhood Services; the parties entered a Consent Decree settling those claims.
- The Consent Decree contained separable sections: Eligibility (initial application processing), Renewal (recertification/renewals), and Early Childhood Services (notice/delivery for already-enrolled children), with termination criteria and retained jurisdiction.
- Over time the court found compliance and vacated/terminated the Eligibility provisions (2009) and the Renewal provisions (2013) after the Affordable Care Act (ACA) changed renewal procedures (introducing passive renewals). The Early Childhood provisions remained in force.
- In 2015–2016 Plaintiffs alleged new ACA-era processing failures and sought a preliminary injunction to provisionally approve applications pending >45 days and to continue renewals; shortly thereafter they moved under Federal Rule of Civil Procedure 60(b)(5)/(6) to “modify” the Consent Decree to obtain the same relief.
- The district court granted the Rule 60(b) motion and imposed ongoing structural relief (provisional approvals and 90-day continuation of eligibility) for all applicants/renewing beneficiaries, until D.C. demonstrated its systems were functioning.
- The D.C. Circuit reversed: it held the district court had imposed a new, sweeping injunction based on new facts and a new statute (the ACA) without satisfying injunction standards and had resurrected or extended relief beyond vacated/terminated Decree provisions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 60(b) authorized the district court to impose the ongoing structural relief Plaintiffs sought (provisional approvals and continuation of renewals) | Salazar argued the court could modify the Consent Decree under Rule 60(b) in light of changed factual circumstances (ACA implementation failures) to protect class members and the remaining Early Childhood obligations | D.C. argued Rule 60(b) cannot be used to create a brand‑new injunction based on new statutory/regulatory obligations and new facts outside the scope of the existing decree | The court held Rule 60(b) cannot be used to impose a new, structural injunction; the district court exceeded its modification power and the new relief was vacated |
| Whether the district court could base new relief on provisions/subclasses of the Consent Decree that had been vacated or terminated | Plaintiffs contended the new relief related to remaining Early Childhood provisions because eligibility affects children’s ability to receive services | D.C. contended the Eligibility and Renewal provisions had been vacated/terminated; the Early Childhood provisions applied only to already‑eligible recipients and did not authorize new eligibility requirements | The court held the district court impermissibly used terminated/vacated provisions as a vehicle to impose obligations addressing eligibility and renewal matters outside the operative decree sections |
| Whether the district court made the required factual findings and applied the traditional injunction standards before imposing classwide structural relief | Plaintiffs relied on record evidence of ACA‑era processing errors and systemic risk to justify ongoing relief without a new preliminary‑injunction procedure | D.C. argued the court lacked findings of widespread, continuing harm, made no adequate factual determinations after adversarial testing, and shifted the burden to D.C. to disprove systemic failure | The court held the district court failed to satisfy injunction preconditions (showing irreparable harm, lack of adequate remedy at law, balance of hardships, public interest) and improperly resolved disputed facts without the protections required for an injunction |
Key Cases Cited
- Frew v. Hawkins, 540 U.S. 431 (2004) (consent decrees must resolve a dispute within the court’s jurisdiction and stem from the case pleadings)
- Rufo v. Inmates of Suffolk Cty. Jail, 502 U.S. 367 (1992) (Rule 60(b) permits modification only for a "significant change" in circumstances and requires tailoring)
- Monsanto Co. v. Geertson Seed Farms, 561 U.S. 139 (2010) (injunctions are extraordinary relief and must meet exacting standards)
- Horne v. Flores, 557 U.S. 433 (2009) (courts must respect separation of powers and not impose ongoing injunctions that unduly bind local officials)
- Pigford v. Veneman, 292 F.3d 918 (D.C. Cir. 2002) (modifications must preserve the essence of the parties’ bargain and cannot expand a decree beyond its negotiated terms)