The United States Supreme Court recently ruled 7-2 to protect the right of Medicaid nursing home residents to seek relief in federal court when state officials do not meet a certain quality of care—a ruling being hailed as a civil rights victory for Medicaid patients. In Health and Hospital Corporation of Marion County v. Talevski, state officials challenged the right of a Medicaid beneficiary to bring suit in federal court in a case involving the alleged violation of Gorgi Talevski’s federal rights under Medicaid’s Federal Nursing Home Reform Act (FNHRA). By a 7-2 margin, in a remarkable opinion for the court authored by Justice Jackson and joined by Chief Justice Roberts and Justices Kagan, Sotomayor, Gorsuch, Kavanaugh, and Barrett, the court preserved federal Medicaid guarantees as privately enforceable legal rights.
What is the Talevski Case?
Gorgi Talevski’s family filed a lawsuit against the Health and Hospital Corp of Marion County, Indiana (HHC), a municipal corporation and political subdivision of the state that operates nursing facilities. The lawsuit alleges that his nursing facility’s use of psychotropic drugs as chemical restraints and involuntary transferring and attempting involuntary discharge to a dementia facility violates the Federal Nursing Home Reform Act (FNHRA). FNHRA establishes the minimum standards of care to which nursing home facilities must follow to participate in the Medicaid program. The Talevski family sued using a federal law known as Section 1983, which parties have used for decades to enforce certain federal rights.
The family argued that “FNHRA’s rights against chemical restraint and involuntary discharge and transfer are enforceable under Section 1983 and that an adverse ruling would be disastrous for federal safety net programs.” A federal district court dismissed the case, ruling that Medicaid enrollees cannot enforce the FNHRA. The Talevski family appealed, and the Seventh Circuit Court of Appeals reversed the district court, allowing the Talevski case to continue. HHC petitioned to have the case heard by the Supreme Court.
The Health and Hospital Corporation of Marion County v. Talevski decision strongly reaffirms the ability of Medicaid enrollees to bring federal lawsuits when state officials violate individual rights guaranteed by federal law. Medicaid provides health insurance for the nation’s poorest and most vulnerable citizens, including children, pregnant people, working-age adults, people with disabilities, and seniors. The rights to be free from unnecessary chemical restraint and to have advance notice of nursing home discharge are just two examples of the coverage guarantees provided to Medicaid enrollees under federal law.
