Rio Grande Community Health Center v. Rullan

397 F.3d 56 (1st Cir. 2005) ; Clearinghouse Number: 55925

Description

Federally Qualified Health Centers Have Private Right of Action Under Section 1983 to Enforce Medicaid Reimbursement Provisions, First Circuit Rules

Abstract

The First Circuit ruled that plaintiffs—federally qualified health centers in Puerto Rico and an individual physician—have a private right of action under 42 U.S.C. § 1983 to enforce “wraparound” reimbursement payments due them under 42 U.S.C. § 1396a(bb)(5), a provision of the Medicaid Act, because that provision mentions federally qualified health centers as a “specific, discrete beneficiary group,” uses rights-creating language, and “speaks in individualistic terms rather than at the aggregate level of institutional policy or practice.” The First Circuit also rejected defendant’s contention that the district court should have abstained due to a parallel proceeding in state court. Plaintiffs sued first in commonwealth court for an order directing defendant to make payments due them and retroactive damages, and later in federal court for declaratory and injunctive relief. One plaintiff sought federal preliminary relief due to its precarious financial situation; the district court granted that plaintiff a preliminary injunction. Defendant appealed, arguing that the district court should have abstained, plaintiff had no cause of action under Section 1983, and the preliminary injunction was otherwise inappropriate. Addressing abstention first, the First Circuit said that Younger v. Harris, 401 U.S. 37 (1971), did not apply because the state proceeding was not a quasi-criminal enforcement action against plaintiff, nor would the federal relief sought interfere with the state proceeding. Furthermore, none of the exceptional circumstances requiring abstention under Colorado River Water Conservation District v. United States, 424 U.S. 800 (1976), was present. Regarding Section 1983, the First Circuit discussed both Blessing v. Freestone, 520 U.S. 329 (1997) (Clearinghouse No. xxxxx), and Gonzaga University v. Doe, 536 U.S. 273 (2002) (Clearinghouse No. xxxxx), and observed that Gonzaga “tightened up” and “relied on somewhat different factors” from Blessing. Applying these factors and noting that the statutory language was “extremely clear and narrow,” the First Circuit affirmed plaintiff’s private right of action.

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Docket Date
2005-02-14 00:00:00+00:00