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Salazar v. District of Columbia
106 F. Supp. 3d 114
D.D.C.
2015
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Background

  • Salazar v. District of Columbia involves a motion to reverse an OAH ruling denying reimbursement for Magnolia Stevenson’s PCA expenses under Medicaid EPDS Waiver.
  • Magnolia Stevenson, 96, with late-stage Alzheimer's, was eligible for eight hours of PCA daily but did not receive services due to ASAP Services’ alleged nonpayment and eventual provider issues.
  • Plaintiffs filed a Class action alleging District’s Medicaid practices caused out-of-pocket expenses that should have been covered.
  • OAH issued a final order denying most post‑January 25, 2014 reimbursement claims; District opposed, Stevenson moved for reconsideration.
  • Court previously established class structure with five sub-classes; only Sub-classes III and IV were implicated in the reimbursement context; Plaintiffs sought Court review of OAH determinations.
  • District argues Magnolia Stevenson isn’t a class member and thus not eligible for direct court review or reimbursement under the Reimbursement Procedures Order.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Standing to sue in court Stevenson has an injury-in-fact and redressable interest. No injury to Stevenson; any relief would accrue to Deborah, not Stevenson. Stevenson has standing; injury and redressability established.
Membership in Salazar class Magnolia should receive relief regardless of class membership. She is not a member of any Salazar sub-class. Not a member of Salazar class; not entitled to class-wide remedies.
Applicability of 1997 Reimbursement Procedures Order Procedures allow direct appeal for all Medicaid recipients with unreimbursed costs. Procedures apply only to class members with eligible-outcome claims (Sub-classes III–IV). Reimbursement Procedures Order does not apply to Magnolia’s claims.

Key Cases Cited

  • Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. (1992)) (standing requires injury, traceability, redressability)
  • CC Distribs., Inc. v. United States, 883 F.2d 146 (D.C. Cir. 1989) (injury in fact and redressability for recoveries)
  • Florida Audubon Soc. v. Bentsen, 94 F.3d 658 (D.C. Cir. 1996) (standing principles applied)
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Case Details

Case Name: Salazar v. District of Columbia
Court Name: District Court, District of Columbia
Date Published: May 18, 2015
Citations: 106 F. Supp. 3d 114; 2015 WL 2404837; 2015 U.S. Dist. LEXIS 64771; Civil Action No. 1993-0452
Docket Number: Civil Action No. 1993-0452
Court Abbreviation: D.D.C.
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