Lovell v. Chandler

No. 98-16545, 98-16548, 99-15928, 99-15930 (9th Cir. Sept. 5, 2002) ; Clearinghouse Number: 54886

Description

Blind and Disabled Persons Who Were Categorically Excluded from Coverage Under Hawaiian Medical Assistance Program Are Entitled to Compensatory Damages

Abstract

The Ninth Circuit has affirmed the district court’s judgment that defendant state’s exclusion of otherwise-qualified persons with disabilities from a state health insurance program violated the Americans with Disabilities Act (ADA). In 1994, the State of Hawaii launched a new program, QUEST, to begin transforming its fee-for-service Medicaid program into a more cost-effective health maintenance organization (HMO)-based plan. Recipients of general assistance and Aid to Families with Dependent Children, as well as participants under the State Health Insurance Program (SHIP), were eligible to receive benefits under QUEST if their income was no more than 300 percent of the federal poverty level, unless they were aged, blind, or disabled. As a result, aged, blind, or disabled persons who met the Medicaid income and asset tests retained their benefits under the old fee-for-service program, but several hundred blind and disabled members of the SHIP population were denied any coverage under QUEST. Plaintiffs claimed that the state’s categorical exclusion of persons with disabilities from the QUEST program violated Title II of the ADA and section 504 of the Rehabilitation Act. The district court granted plaintiffs’ motion for partial summary judgment, finding that the state’s action was discriminatory. The court also partially granted plaintiffs’ motion for class certification and held that the state was liable for compensatory damages. The state appealed. The court of appeals held that the Rehabilitation Act is a valid exercise of Congress’s spending power and therefore the Eleventh Amendment is not a bar to individual plaintiffs’ section 504 claims against the state. The court noted that Congress has a strong interest in ensuring that federal funds are not used in a discriminatory manner and in holding states responsible when they violate funding conditions. The court also held that plaintiffs had established a prima facie case of violations of both Title II of the ADA and section 504. The court rejected the state’s argument that plaintiffs were not denied meaningful access to public benefits because the fee-for-service program continued to be available after QUEST was implemented. Finally, the court held that, because the state acted with deliberate indifference and therefore engaged in intentional discrimination, plaintiffs are entitled to compensatory damages.

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Attorney Information
Docket Date
2002-09-05 00:00:00+00:00

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