Injunctive Relief – Medicaid Programs

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7^th Circuit Court of Appeals

Case Name: Karen Vaughn v. Jennifer Walthall, et al.,

Case No.: 19-1244

Officials: BAUER, EASTERBROOK, and WOOD, Circuit Judges.

Focus: Injunctive Relief – Medicaid Programs  

Federal law prohibits discrimination against persons with disabilities, and in furtherance of that goal, it requires states to administer public programs “in the most integrated setting appropriate to the needs of qualified individuals with disabilities.” That duty is bounded by the standard of reasonableness; states are not obligated fundamentally to alter their programs to comply.

At issue here is whether the anti‐discrimination mandate compels a state to structure and fund its Medicaid programs in a manner that ensures that all Medicaid recipients who desire to receive health care in a home setting may do so regardless of cost to the state. In addition, we must decide how, if at all, the state’s adoption after oral argument of a pilot program that provides greater flexibility to those who want home health care affects this case. We conclude that we still face a live controversy but that further proceedings are necessary. We also conclude that the permanent injunction issued by the district court swept too broadly. If any injunction is still warranted—a question on which we take no position—it must be narrowly tailored to any violations that are proven.

Vacated and remanded

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Derek A Hawkins is trademark corporate counsel for Harley-Davidson. Hawkins oversees the prosecution and maintenance of the Harley-Davidson’s international trademark portfolio in emerging markets.