Salazar v. District of Columbia
991 F. Supp. 2d 34
D.D.C.2013Background
- This 1993 class action against the District of Columbia challenged Medicaid due process in recertification.
- The 1996 Findings of Fact and Conclusions of Law granted some claims and denied others.
- A 1997 comprehensive remedial order followed the court’s rulings.
- On Sept. 20, 2013, defendants moved to modify the Jan. 25, 1999 Consent Order to be relieved from Section III due to ACA conflicts.
- Plaintiffs filed motions Sept. 30, 2013 to partially stay recertification provisions and Oct. 1, 2013 for limited discovery related to ACA.
- The court granted the motion to modify Section III, concluding ACA creates a significant change in circumstances and that continued enforcement would be detrimental to the public interest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 60(b)(5) modification is appropriate. | Salazar argues continued Section III is still equitable. | DC contends ACA creates significant change making enforcement inequitable. | Yes; modification granted. |
| Does ACA require termination of Section III due to conflicts? | Salazar asserts potential protection of due process rights. | DC maintains ACA overrides inconsistent provisions. | Yes; Section III terminated. |
| Are due process rights of beneficiaries adequately protected during transition? | Plaintiffs seek discovery and modifications to safeguard rights. | Discovery denied as moot; rights protected by ACA regulations. | Rights adequately protected; discovery denied as moot. |
| Do ACA safe harbor provisions apply to 2013–2014 renewals? | Plaintiffs fear gaps in protection without clear interpretation. | Regulations apply to October–December 2013 renewals. | Covered by ACA safe harbor guidance; no further action needed. |
Key Cases Cited
- Horne v. Flores, 557 U.S. 433 (2009) (flexible modification standard for institutional reform decrees)
- Rufo v. Inmates of Suffolk Cty. Jail, 502 U.S. 367 (1992) (standard for modifying consent decrees; need to show change in circumstances)
- Frew v. Hawkins, 540 U.S. 431 (2004) (support for flexible approach in changes to remedies)
- Petties ex rel. Martin v. Dist. of Columbia, 662 F.3d 564 (2011) (DC Cir. on flexible modification and duration of decrees)
- Salazar ex rel. Salazar v. Dist. of Columbia, 633 F.3d 1110 (2011) (DC Cir. extraordinary circumstances in Rule 60(b)(6))