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Broselow v. Fisher
No. 01-3933 (3d Cir. Feb. 11, 2003) ; Clearinghouse Number: 55138
Description
Medicaid Recipients Not Entitled to Tobacco Settlement Funds Because Funds Were Not Collected Under Assignment from Recipients, Third Circuit Holds
Abstract
The Third Circuit affirmed the district court’s dismissal of
this action brought by Medicaid recipients seeking monies from the
1998 tobacco settlement that concluded the Commonwealth of
Pennsylvania’s lawsuit against major tobacco companies. The
companies agreed to pay Pennsylvania more than $11 billion.
Plaintiffs, a class of Medicaid recipients with various
smoking-related illnesses, sought to have Pennsylvania comply with
42 U.S.C. § 1396k(b), which plaintiffs argued required the
commonwealth to pay them whatever portion of the tobacco settlement
was not used to reimburse the commonwealth for its Medicaid
expenses. The district court granted Pennsylvania’s motion to
dismiss for failure to state a claim on the grounds that the
Eleventh Amendment barred the suit. Plaintiffs appealed. The Third
Circuit held that Section 1396k(b) did not authorize the relief
that plaintiffs sought because the funds from the tobacco
settlement were not collected under an assignment from plaintiffs.
Moreover, the court found that, even if collected on assignment, a
1999 amendment to the Medicaid Act, 42 U.S.C. §
1396b(d)(3)(B)(ii), barred plaintiffs’ claims to any portion
of the tobacco settlement. That amendment allowed the states to use
the funds from the tobacco settlement for any purpose that the
states found appropriate.
