Westside Mothers v. Haveman

___ F.3d ___, 2002 FED App. 0172, 2002 U.S. App. LEXIS 9159 (6th Cir. 2002)

May 16, 2002


In Westside Mothers v. Haveman, a far reaching Medicaid and federal/civil rights law decision issued on May 16, 2002, the sixth circuit federal court of appeals reversed the district court’s grant of summary judgment on all substantive law issues and partially reversed on the issue of standing for organizational plaintiffs.

The case was filed under 42 U.S.C. §1983 alleging that the state of Michigan failed to provide services required by the Medicaid program – specifically the “early periodic screening, diagnostic and treatment services … for individuals who are eligible under the plan and are under the age of 21.”

The key issues in the case are:

  • Whether Medicaid is only a contract – the circuit held that pursuant to statutes upon states participating in Medicaid and similar programs – those programs are not merely contract provisions, but federal laws
  • Whether acts passed under the spending power are the supreme law – the circuit rejected the district court’s argument and found that acts passed under Congress’ spending power are supreme law, a principle that has not been abandoned in recent decisions.
  • Whether the suit is barred by sovereign immunity – the circuit court found that Ex Parte Young provided a foundation for an exception to the sovereign immunity doctrine.
  • Whether there is a private right of action under § 1983 – again, the circuit rejected the district court’s third party beneficiary theory and held that the Supreme Court’s Blessing v. Freestone three part analysis allowed the plaintiffs in this case to proceed as an intended beneficiary of the provision.

This important decision reaffirms the position that Medicaid beneficiaries and providers can enforce provisions of the federal Medicaid Act in federal court.

The decision may be accessed through on line services (LEXIS, Westlaw), or by going tohttp://pacer.ca6.uscourts.gov/cgi-bin/getopn.pl?OPINION=02a0172p.06

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