Salazar v. District of Columbia
177 F. Supp. 3d 418
D.D.C.2016Background
- This is a long‑running class action (Salazar) challenging the District of Columbia’s administration of Medicaid; a 1999 Settlement Order remedied violations including delayed application processing and inadequate renewal/notice procedures; portions addressing applications and renewals were later vacated (2009, 2013) after ACA changes.
- After ACA implementation and migration to a new DC Access System (DCAS), Plaintiffs documented widespread technical and administrative failures (stuck/malformed electronic cases, transfer errors to legacy ACEDS, lost/scanned documents, mailing/address defects) that left thousands without timely application decisions or renewals.
- Plaintiffs moved (Dec 2015–Feb 2016) for (a) a preliminary injunction requiring provisional approval of applications pending >45 days and (b) an order continuing eligibility during renewals; they also sought a permanent modification of the Settlement Order to impose similar relief until the District proves system reliability.
- The District made substantial remediation progress (eliminating many backlogs by Feb 2016) and offered retroactive approvals in many cases, but the Court found the underlying systemic risks and harms (including loss of care) persisted and could recur.
- The Court treated the Rule 65 and Rule 60(b)(5)/Rufo framework as applicable, concluded changed circumstances (ACA implementation + system failures) warranted modification of the consent decree, granted Plaintiffs’ Motion for Modification with tailoring, and denied the preliminary injunction as moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether changed circumstances justify modifying the Settlement Order under Rule 60(b)(5)/Rufo | ACA implementation and DCAS failures created significant, unforeseeable harms to class members that require renewed injunctive relief | Relief would impermissibly revive terminated Sections II/III, exceed court's supervisory role, and hinder local administration | Court: significant change in circumstances exists (ACA + system failures); modification warranted under Rufo |
| Whether proposed remedies are suitably tailored | Plaintiffs: provisional approvals for >45‑day pending apps and continuation of eligibility during renewals will prevent irreparable harm | District: second prong is overbroad (would indefinitely continue benefits of ineligible persons) and risks waste/abuse; U.S. may be a necessary party | Court: first prong appropriate; second prong narrowed to a 90‑day continuation unless District affirmatively determines ineligibility; monthly reporting not required |
| Whether relief would improperly bind or require joining the United States (necessary party) | Plaintiffs seek relief only against the District; federal reimbursement prospects do not make the U.S. a necessary party | District argued federal funding/reimbursement makes U.S. a necessary party and limits injunction scope | Court: no authority presented to require joinder; rejected argument as barrier to relief |
| Whether recent remediation by the District defeats need for relief | Plaintiffs: progress does not guarantee durability; oversight needed until systems proven reliable | District: fixes eliminated backlogs and thus injunctive relief is unnecessary and intrusive | Court: progress acknowledged but not dispositive; relief remains justified and is limited in duration/terminating mechanism |
Key Cases Cited
- Salazar v. District of Columbia, 954 F. Supp. 278 (D.D.C. 1996) (original merits findings on application processing, notice, and EPSDT obligations)
- Rufo v. Inmates of Suffolk Cty. Jail, 502 U.S. 367 (1992) (standard for modifying consent decrees under Rule 60(b)(5))
- United States v. W. Elec. Co., 46 F.3d 1198 (D.C. Cir. 1995) (court’s continuing power to modify decrees and practical guidance on consent‑decree modification)
- Twelve John Does v. District of Columbia, 841 F.2d 1133 (D.C. Cir. 1988) (rule that Rule 60(b)(5) applies only to orders with prospective application)
- Horne v. Flores, 557 U.S. 433 (2009) (emphasizing prompt return of authority to local officials when circumstances warrant modification of remedy)