Rodde v. Bonta

357 F.3d 988 (9th Cir. 2004) ; Clearinghouse Number: 55598

Description

Ninth Circuit Affirms Injunction Against County’s Closure of Rehabilitative Care Facility and Finding of Plaintiffs’ Likely Success on ADA Claim

Abstract

The Ninth Circuit affirmed the district court’s preliminary injunction barring Los Angeles County from proceeding with plans to close Rancho Los Amigos National Rehabilitation Center, a county hospital dedicated primarily to providing inpatient and outpatient rehabilitative care to people with disabilities. The Ninth Circuit ruled that the district court did not abuse its discretion in concluding that plaintiffs were likely to succeed on the merits of their claims under the Americans with Disabilities Act (ADA). Shortly after consolidating clinical services for severe disabilities at Rancho, defendants proposed to close the facility to reduce health care spending. Plaintiff class of current and future Medicaid recipients who lived in the county, had disabilities, and needed Rancho’s rehabilitative services sued. The district court found that if Rancho closed, plaintiffs would be unable to obtain substitute care elsewhere and that closure would violate federal law. On defendants’ appeal, the Ninth Circuit found defendant county’s reliance on Alexander v. Choate, 469 U.S. 287 (1985), “unpersuasive.” The Ninth Circuit said that Alexander, which upheld a state’s reduction in inpatient days covered by Medicaid, was distinguishable because the reduction applied to all patients. “Eliminating entirely the only hospital … that focuses on the needs of disabled individuals … and that provides services disproportionately required by the disabled” was not facially neutral, the Ninth Circuit said. Defendants’ planned cuts specifically targeted services for the disabled, an approach prohibited by the ADA. While defendant’s interest in balancing its health care budget was strong, plaintiffs’ evidence suggested that closing Rancho would likely increase costs because plaintiffs would have to be treated somewhere.

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Attorney Information
Docket Date
2004-02-05 00:00:00+00:00

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