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Egan v. Davis
No. 97-1184 (7th Cir. June 25, 1997) ; Clearinghouse Number: 52201
Description
Seventh Circuit Vacates Judgment Voiding Indiana’s Policy Allowing Agency to Appeal Administrative Decisions Favorable to Medicaid Claimants
Abstract
The Seventh Circuit has vacated the district court’s judgment
in this class action challenging the Indiana Department of Social
Services (DSS)’s provisions for appellate review of
plaintiffs’ Medicaid claims. Plaintiffs alleged that
DSS’s procedures, which allowed the state or its fiscal
intermediary to appeal administrative law judge decisions that were
favorable to claimants, violated 42 C.F.R. § 431.205(b). Named
plaintiffs’ claims for Medicaid benefits were resolved in
their favor pending the district court’s ruling on
plaintiffs’ motion for class certification. Subsequently, the
district court enjoined DSS from modifying and/or reversing any
decisions issued by administrative law judges that were favorable
to Medicaid applicants and/or recipients. DSS appealed. The court
of appeals held that, because named plaintiffs did not suffer
monetary injury from the administrative appeals of their claims,
and because the class was not certified while named
plaintiffs’ administrative appeals were pending,
plaintiffs’ claims were moot. Accordingly, the court vacated
the district court’s judgment and remanded the case with
instructions to dismiss the complaint for lack of a case or
controversy.
