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