Cases

Question 1

National Federation of Independent Business v. Sebelius

Answer 1

(1) The individual mandate contained in the Patient Protection and Affordable Care Act of 2010 is a valid use of Congress’s power to tax.

(2) The Medicaid expansion provision of the Patient Protection and Affordable Care Act of 2010 is not a constitutional use of Congress’s spending powers.

Question 2

King v. Burwell

Answer 2

(1) In extraordinary cases involving questions of deep economic and political significance, a court does not grant an administrative agency Chevron deference.

(2) The Affordable Care Act’s tax credits are available in states that have exchanges established by the Department of Health and Human Services.

Question 3

Bellevue Hospital Center v. Leavitt

Answer 3

Facts:

-Medicare reimburses hospitals for the costs provided to its’ beneficiaries (elderly/some disabled).

-Congress eventually changed the hospital payment system from one that reimbursed hospitals for actual costs spent to one that paid fixed rates based on expected expenditures.

-Each geographic area would receive a certain payout based on estimated costs.

-The geographical areas were called Metropolitan Statistical Areas (MSAs) and the Centers for Medicare and Medicaid Services (CMS) was responsible for managing the MSA system.

-the sizes of the MSAs were downsized except for the New York MSA which was expanded to include portions of northern New Jersey hospitals that paid lower wages.

-Consequently, New York hospitals stood to receive much less money in fixed-rate reimbursement.

-Congress directed CMS to collect data on hospital occupational mixes, i.e. the numbers of nurses, staff, specialists, etc., to better refine and define hospital geographic areas. CMS failed to obtain the data by the date Congress set.

-Bellevue Hospital Center (Bellevue) and several other hospitals (plaintiffs) filed suit against the Secretary of the U.S. Department of Health and Human Services, Leavitt (defendant).

Issue:
1. Whether Congress spoke directly to the question at issue?

2. Whether the action taken by CMS was arbitrary, capricious, or an abuse of discretion?

Holding:

Use of MSAs to fill the gap left by the ambiguous term geographic areas is reasonable

Question 4

Westside Mothers v. Haveman

Answer 4

Facts:

-Alleging that the state of Michigan has failed to provide services required by the Medicaid Program → against the director of Michigan Department of Community Health

-Westside Mothers argued that Haveman (director of MDCH) did not provide the early and periodic screening and tx services mandated by the Medicaid Act

-Sued under Section 1983: creates a cause of action against any person who under color of state law deprives an individual of any right, privileges, or immunities secured by the Constitution and laws of the US

Issues:

1. Whether Medicaid is only a contract?
2. Whether the suit is barred under sovereign immunity?
3. Whether there is a private right of action under § 1983?

Holdings:

1. Medicaid is not a contract, but governing law of the land
2. Ex Parte Young: A suit alleging a violation of federal law that names a state official as a defendant and seeks only equitable relief isn’t considered a suit against the state and isn’t barred by sovereign immunity.
3. Westside Mothers had a private right of action under Section 1983. The provisions were clearly intended to benefit the public, were binding obligations on Mich., the provisions are not vague

Question 5

Armstrong v. Exceptional Child Center