October 23, 2012

Case Highlights 2005-2006 Term

Following are case highlights for the topic areas of Medicaid, Patent Law, and Prisoners' Rights. To access other case highlights for the 2005-2006 Term or previous terms, or to return to the main Case Highlights page, use the Topic Area menu to the right.


Arkansas Department of Health and Human Services v. Ahlborn
Docket No. 04-1506
Affirmed: The Eighth Circuit

Argued: February 27, 2006
Decided: May 1, 2006
For Case Analysis: See ABA Preview 247

Can states obtain reimbursement for Medicaid expenses for the unallocated proceeds of personal injury settlements?

No. The Court held that federal Medicaid law does not authorize the state department of health and human services to assert a lien on the respondent's personal-injury settlement more than the portion of the respondent's settlement that represents medical expenses. Arkansas' third-party liability provisions are unenforceable insofar as they compel a different conclusion.

From the opinion by Justice Stevens (for a unanimous Court):

There is no question that the State can require an assignment of the right, or chose in action, to receive payments for medical care. So much is expressly provided for by §§1396a(a)(25) and 1396k(a). And we assume, as do the parties, that the State can also demand as a condition of Medicaid eligibility that the recipient "assign" in advance any payments that may constitute reimbursement for medical costs. To the extent that the forced assignment is expressly authorized by the terms of §§1396a(a)(25) and 1396k(a), it is an exception to the anti-lien provision. … But that does not mean that the State can force an assignment of, or place a lien on, any other portion of Ahlborn's property. … [T]he exception carved out by §§1396a(a)(25) and 1396k(a) is limited to payments for medical care. Beyond that, the anti-lien provision applies.

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Laboratory Corporation of America Holdings v. Metabo-Lite Laboratories Inc. et al.

Docket No. 04-607

Dismissed: The writ of certiorari to the Federal Circuit

Argued: March 21, 2006

Decided: N/A

For Case Analysis: See ABA Preview 298

From the June 22, 2006, per curiam opinion:

The writ of certiorari is dismissed as improvidently granted.

Taking no part in the consideration or decision of this case: Chief Justice Roberts

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Beard v. Banks

Docket No. 04-1739

Reversed: The Third Circuit

Argued: March 27, 2006

Decided: June 28, 2006

For Case Analysis: See ABA Preview 339

Did prison officials violate the First Amendment rights of inmates in a high-security unit by depriving them of access to secular newspapers and magazines?

No. Restrictive prison regulations are permissible if they are "reasonably related to legitimate penological interests." Prison officials in this case set forth adequate legal support for their policy and the prisoner failed to show specific facts that could warrant a determination in his favor.

From the opinion by Justice Breyer (joined by Chief Justice Roberts and Justices Kennedy and Souter):

The Secretary [of the Pennsylvania Department of Corrections] in his motion set forth several justifications for the prison's policy, including the need to motivate better behavior on the part of particularly difficult prisoners, the need to minimize the amount of property they control in their cells, and the need to assure prison safety, by, for example, diminishing the amount of material a prisoner might use to start a cell fire. We need go no further than the first justification, that of providing increased incentives for better prison behavior. Applying ... well-established substantive and procedural standards ... we find, on the basis of the record before us, that the Secretary's justification is adequate. And that finding here warrants summary judgment in the Secretary's favor.

Concurring in the judgment: Justice Thomas (joined by Justice Scalia)

Dissenting: Justice Stevens (joined by Justice Ginsburg)

Dissenting: Justice Ginsburg

Taking no part in the consideration or decision of the case: Justice Alito

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Woodford et al. v. Ngo

Docket No. 05-416

Reversed and Remanded: The Ninth Circuit

Argued: March 22, 2006

Decided: June 22, 2006

For Case Analysis: See ABA Preview 343

Does the Prison Litigation Reform Act's (PLRA) requirement that prisoners exhaust all available administrative remedies require prisoners to file administrative grievances or appeals in a timely manner consistent with procedural rules?

Yes. The PLRA's exhaustion requirement requires prisoners to complete the administrative review process in accordance with the applicable procedural rules, including deadlines.

From the opinion by by Justice Alito (joined by Chief Justice Roberts, and Justices Scalia, Kennedy, and Thomas:

The text of 42 U. S. C. §1997e(a) strongly suggests that the PLRA uses the term "exhausted" to mean what the term means in administrative law, where exhaustion means proper exhaustion. Section 1997e(a) refers to "such administrative remedies as are available," and thus points to the doctrine of exhaustion in administrative law. … Construing §1997e(a) to require proper exhaustion also fits with the general scheme of the PLRA, whereas respondent's interpretation would turn that provision into a largely useless appendage. The PLRA attempts to eliminate unwarranted federal-court interference with the administration of prisons, and thus seeks to "affor[d] corrections officials time and opportunity to address com-plaints internally before allowing the initiation of a federal case.

Concurring in the judgment: Justice Breyer

Dissenting: Justice Stevens (joined by Justices Souter and Ginsburg)

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