Wicomico Nursing Home v. Lourdes Padilla, 910 F.3d 739

Background

Four Maryland nursing homes sued state Medicaid and human services secretaries on behalf of eleven residents, alleging wrongful Medicaid denials and defective administration of the Medicaid application/reactivation process.
Claims asserted: Fourteenth Amendment due process, the Medicaid Act, Title II of the ADA, and Section 504 of the Rehabilitation Act; remedies sought included retroactive approval/payment of Medicaid benefits, injunctive/declaratory relief, and damages.
District court dismissed the complaint for lack of subject‑matter jurisdiction (Eleventh Amendment and mootness) and for failure to state a due process claim; declined initially to address ADA/Rehab Act claims but later denied a Rule 59(e) motion, dismissing those claims as well.
On Rule 59(e) review the district court recognized ADA/Rehab Act claims are not Eleventh Amendment‑barred but held the nursing homes lacked standing as real parties in interest and, alternatively, failed to plead disability or causation plausibly under Rule 12(b)(6).
The Fourth Circuit consolidated appeals and affirmed: retrospective relief (retroactive payments) barred by Eleventh Amendment; prospective relief moot because living residents now receive Medicaid and some residents are deceased; ADA/Rehab Act claims affirmed dismissed (appellants waived standing argument and failed Rule 12(b)(6) pleading).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Eleventh Amendment bars suit for retroactive Medicaid payments	Nursing homes sought retroactive approval/payments; argued Ex Parte Young permits injunctive relief against officials	Secretaries argued retroactive payments are retrospective relief barred by Eleventh Amendment	Retroactive monetary relief is retrospective and barred by Eleventh Amendment (Eleventh Amendment precludes such relief)
Whether injunctive/declaratory relief survives Eleventh Amendment (prospective relief)	Requested injunctions declaring program unlawful and ordering future approvals/payments	Secretaries argued any prospective relief either is not sought or is moot given current circumstances	Even assuming some relief would be prospective, claims are moot because living residents now receive Medicaid and deceased residents cannot obtain prospective relief; court lacks jurisdiction
Standing to bring ADA and Rehab Act claims on residents' behalf	Nursing homes sued as assignee/authorized representative for residents	Secretaries argued nursing homes not real parties in interest; thus no standing	Nursing homes did not contest standing on appeal (waived); district court's standing dismissal affirmed
Sufficiency of ADA/Rehab Act pleadings under Rule 12(b)(6)	Complaint alleged residents were "qualified individuals with a disability" and suffered discrimination from program administration	Defendants argued pleadings are conclusory, fail to allege specific disabilities or that disability motivated denial; Rehab Act requires stricter causation	Complaint fails Rule 12(b)(6): conclusory disability allegation insufficient and no plausible allegation that disability motivated denial; ADA and Rehabilitation Act claims dismissed

Key Cases Cited

Pashby v. Delia, 709 F.3d 307 (4th Cir. 2013) (overview of Medicaid as federally conditioned state program)
Ex Parte Young, 209 U.S. 123 (U.S. 1908) (permit injunctions against state officials for ongoing federal‑law violations)
Edelman v. Jordan, 415 U.S. 651 (U.S. 1974) (retrospective relief against states barred by Eleventh Amendment)
Quern v. Jordan, 440 U.S. 332 (U.S. 1979) (limitations on Ex Parte Young where injunctions have ancillary treasury effects)
Kimble v. Solomon, 599 F.2d 599 (4th Cir. 1979) (retroactive Medicaid payments constitute barred retrospective relief)
Antrican v. Odom, 290 F.3d 178 (4th Cir. 2002) (injunctions ordering future compliance with Medicaid Act viewed as prospective)
Idaho v. Coeur d’Alene Tribe of Idaho, 521 U.S. 261 (U.S. 1997) (distinguishing remedies aimed at past violations)
Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility standard for pleadings)
Heiko v. Colombo Sav. Bank, F.S.B., 434 F.3d 249 (4th Cir. 2006) (elements for establishing disability under ADA)