Filed Date: Jan. 15, 2008
Closed Date: 2012
Clearinghouse coding complete
On January 15, 2008, a group of Medicaid-eligible adults with disabilities that were confined to a nursing-home facility filed a class action in the U.S. District Court for the Northern District of Florida under the ADA and the Rehabilitation Act against the state's Health Care Administration and Department of Elder Affairs. The plaintiffs, represented by public interest attorneys, asked the Court for declaratory and injunctive relief, alleging that the state discriminated against them by failing to offer services that would enable them to live in a community setting.
On June 7, 2008, the Court (Judge Robert L. Hinkle) denied defendants' motion to dismiss. On October 14, 2008, Judge Hinkle certified the class consisting of any Florida Medicaid-eligible adult who, at any time during the litigation, resided in a nursing home that received Medicaid funding, and who could and would have resided in the community with appropriate community-based services.
At the same time, the judge granted a preliminary injunction with regard to one of the named plaintiffs, Clayton Griffith. Griffith lived in a nursing home, the cost of which was covered by the state's Medicaid program. He had applied for and been determined eligible for a waiver that should have allowed him to live in the community rather than an institution. But the state's long waiting list precluded him from accessing the program. Nevertheless, he moved out of the home and into an apartment. Judge Hinkle entered an injunction ordering the state to provide Griffith Medicaid coverage for a certified nursing assistant. The state appealed the preliminary injunction, which the 11th Circuit affirmed on June 22, 2010.
The parties cross-moved for summary judgment; the judge denied both motions on January 19, 2011.
After a February 2011 bench trial, Judge Hinkle issued an order and opinion on January 3, 2012 that made permanent the injunction regarding Griffith, dismissed the other named plaintiffs' claims as moot, and decertified the class. To start, all but one of the other named plaintiffs had died during the course of litigation; the remaining one had decided to stay in the nursing home. The judge decertified the class in part because the state legislature had passed a new law which greatly improved the rate at which Medicaid-eligible adults were transitioned from nursing homes to community living. Post-legislation, Judge Hinkle reasoned, it was no longer true that the state had refused to act on grounds that applied generally to the class. He concluded that where the conditions that made class-certification appropriate are no longer present, the court has discretion to decertify, which he chose to do.
Summary Authors
Kunyi Zhang (2/5/2011)
Andrew Junker (10/22/2014)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/4816258/parties/lee-v-benson/
Birch, Stanley F. Jr. (Georgia)
Canan, Stacy (District of Columbia)
Chonin, Neil (Florida)
Bennett, Kelly Ann (Florida)
Blocker, William Michael II (Florida)
Birch, Stanley F. Jr. (Georgia)
Edmondson, James Larry (Georgia)
Hinkle, Robert Lewis (Florida)
Hodges, William Terrell (Florida)
Sherrill, William C. Jr. (Florida)
See docket on RECAP: https://www.courtlistener.com/docket/4816258/lee-v-benson/
Last updated July 4, 2023, 3:07 a.m.
State / Territory: Florida
Case Type(s):
Public Benefits/Government Services
Special Collection(s):
Key Dates
Filing Date: Jan. 15, 2008
Closing Date: 2012
Case Ongoing: No
Plaintiffs
Plaintiff Description:
A group of Florida residents who were Medicaid eligible adults with disabilities but were currently confined to a nursing facility.
Plaintiff Type(s):
Attorney Organizations:
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Granted
Defendants
Case Details
Causes of Action:
Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.
Section 504 (Rehabilitation Act), 29 U.S.C. § 701
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Preliminary injunction / Temp. restraining order
Source of Relief:
Order Duration: 2012 - 0
Content of Injunction:
Implement complaint/dispute resolution process
Issues
General:
Access to public accommodations - governmental
Habilitation (training/treatment)
Public benefits (includes, e.g., in-state tuition, govt. jobs)
Discrimination-basis:
Disability (inc. reasonable accommodations)
Disability:
Mental Disability:
Intellectual/developmental disability, unspecified
Medical/Mental Health:
Type of Facility:
Benefit Source: