Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals affirming the final order of the Commissioner of the Department of Human Services' (DHS) concluding that Trinity had engaged in the abuse outlined in DHS's notices and spreadsheets, holding that the first report of the administrative law judge (ALJ) was the binding decision in this matter.Trinity Home Health Care, which provided nursing and personal care assistant services, received reimbursement from DHS for services that it provided to Medicaid-eligible people with disabilities. After an investigation, DHS sent Trinity notices of termination from the program and demanding return of overpayments and payment-withholding. Both before and after remand by the Commissioner, the ALJ found that terminating Trinity's participation in the Minnesota Health Care Programs was an inappropriate sanction for Trinity's failure to provide certain records. The Commissioner modified the report, concluding that Trinity had engaged in the abuse alleged by the DHS. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Commissioner did not have the authority to remand the case due to the DHS's general authority to administer and supervise Medicaid; and (2) the Commissioner did not have implied authority to remand the case to the ALJ under case law. View "In re Surveillance & Integrity Review Appeals by Trinity Home Health Care Services" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court concluding that federal regulations implementing the federal Health Insurance Portability and Accountability Act (HIPAA) is a "specific authorization in law" under Minn. Stat. 144.293, subd. 2(2), holding that the court of appeals did not err.After Children's Health Care informed Appellants that their child's protected health information was disclosed to Children's institutionally-related foundation and its business associate for fundraising purposes Appellants sued, arguing that Children's violated the Minnesota Health Records Act, Minn. Stat. 144.291-.298. The district court granted summary judgment for Children's, concluding that the disclosure of the patient's health information was specifically authorized in law by federal regulations implementing HIPAA. The court of appeals affirmed. The Supreme Court affirmed, holding that the disclosure of the health information at issue was permitted by a "specific authorization in law," as that phrase is used in the Minnesota Health Records Act. View "Schneider v. Children's Health Care" on Justia Law

In this dispute over Governor Walz's declaration of a peacetime emergency under the Emergency Management Act, Minn. Stat. 12.01-.61, and the executive order the Governor issued requiring that Minnesotans wear face coverings, the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals dismissing the appeal as moot, holding that one issue on appeal met a mootness exception.Plaintiffs brought the underlying petition for a writ of quo warranto challenging the face-covering mandate, arguing that the Governor overstepped his powers under the Emergency Management Act and that the mask mandate violated several of their constitutional rights. The district court granted Defendants' motion to dismiss. While Plaintiffs' appeal was pending, the peacetime emergency and mask mandate ended. Consequently, the court of appeals dismissed the appeal as moot. The Supreme Court reversed in part, holding (1) the legal question of whether the Act authorizes a peacetime emergency for a public health emergency is functionally justiciable and an important issue of statewide significance that should be decided immediately; and (2) Plaintiffs' remaining challenges to the mask mandate did not meet any of the mootness exceptions. View "Snell v. Walz" on Justia Law

The Supreme Court reversed the decision of the court of appeals and remanded this case, holding that, for property to be commandeered, the government must exercise exclusive control over or obtain exclusive possession of the property such that the government could physically use it for an emergency management purpose.Appellant brought this suit arguing that his hospitality businesses were commandeered when the Governor issued emergency executive orders in response to the COVID-19 pandemic that imposed capacity limits for dining beginning in March 2020. As the owner of the commandeered property, Appellant argued, he was entitled to just compensation for the government's use under Minn. Stat. 12.34. The district court dismissed the commandeering claim, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the government exercises exclusive physical control or exclusive possession of private property when only the government may exercise control or possession of the property and the owner is denied all control over or possession of the property; and (2) remand to the district court for further proceedings was required in this case. View "Buzzell v. Walz" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the order of the district court that non-homestead life estates should not be included in Marvin Schmalz's assets, holding that the term "individual" in Minn. Stat. 256B.056, subd. 4a applies only to the applicant for medical assistance.Esther Schmalz was living at a long-term-care facility when she submitted an application for medical assistance for long-term-care benefits. As part of the assessment of her husband Marvin's assets, Renville County Human Services (RCHS) included Marvin's portion of several non-homestead life estate interests that he and Esther owned. Esther appealed, arguing that the life estates should not be included in the total amount of assets that Marvin may retain. The human services judge concluded that RCHS properly denied Esther's application for medical assistance based on the inclusion of the life estate assets owned by Marvin. The Commissioner of Minnesota Department of Human Services adopted the human services judge's recommendation. The district court concluded that the non-homestead life estates should not be included in Marvin's assets, ruling that the term "individual" in section 256B.056, subd. 4a included Marvin. The Supreme Court reversed, holding that an "individual" in the statute refers to the medical assistance applicant and not a community spouse. View "In re Schmalz" on Justia Law

The Supreme Court reversed the decision of the Commissioner of Human Services determining that RS Eden, a supervised living facility where J.W. received treatment before voluntarily leaving and dying of a drug overdose five days later, was responsible for maltreatment of J.W. by neglect, holding that the Commission's decision was not supported by substantial evidence.RS Eden appealed the maltreatment determination to the court of appeals, which affirmed. The Supreme Court reversed, holding that that Commissioner's finding of maltreatment for neglect for RS Eden's failure to obtain a waiver or to confer with a prescribing physicians was not supported by substantial evidence because RS Eden complied with the rules regarding the disposition of controlled substances and took reasonable steps to protect its client. View "In re Appeal by RS Eden" on Justia Law

Appellant BCBSM, Inc. (“Blue Cross”) denied respondent James Linn’s insurance claim because the requested treatment was not considered medically necessary under the parties’ health-plan contract. After Blue Cross denied the claim, an external-review entity determined that the treatment was, in fact, medically necessary for Linn’s condition. Blue Cross paid the claim, but Linn and his wife sued Blue Cross for breach of contract. The district court granted summary judgment for Blue Cross, concluding that the treatment was not medically necessary under the contract’s plain terms and that Blue Cross fulfilled its contractual obligations when it paid for the treatment following the external review. The court of appeals reversed. Because the Minnesota Supreme Court concluded: (1) external-review decisions were independent determinations of medical necessity that did not supersede contractual definitions of medical necessity; and (2) the health-plan contract plainly excluded coverage for Linn’s claim for treatment, the Court reversed. View "Linn v. BCBSM, Inc." on Justia Law

The Minnesota Department of Human Services (DHS) assessed surcharges against seven hospitals and hospital systems (collectively, the Hospitals) on their net patient revenue under Minn. Stat. 256.957(2). The Hospitals appealed their surcharge assessments for various months, alleging that federal law preempted the surcharge to the extent it required them to pay a surcharge on revenues obtained from insurance carriers that participated in the Federal Employee Health Benefits Program and the TRICARE program. The Commissioner of DHS denied the claim. The court of appeals affirmed. The Supreme Court affirmed, holding that the surcharge was not preempted by federal law. View "In re Consolidated Hosp. Surcharge Appeals of Gillette Children’s Specialty Healthcare" on Justia Law

Kirk Lloyd sought to be admitted at United Hospital to stop his pattern of self-harm. United informed Lloyd and his mother, Melinda Binkley, that Lloyd would not be admitted to United’s inpatient mental-health program and released Lloyd. The next night, Lloyd committed suicide. Binkley, acting as trustee, filed a medical-malpractice action against Allina Health System and its staff (collectively, Respondents) alleging that Respondents’ negligent failure to properly examine, evaluate, and provide services to Lloyd caused his death. Respondents filed a motion for summary judgment, arguing that they were entitled to immunity for their good-faith actions under the Minnesota Commitment and Treatment Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Respondents’ good-faith decision to deny Lloyd admission to the inpatient mental health unit is entitled to immunity; but (2) it is not clear that Respondents are entitled to summary judgment on all of Binkley’s claims. Remanded. View "Binkley v. Allina Health System" on Justia Law

Kirk Lloyd sought to be admitted at United Hospital to stop his pattern of self-harm. United informed Lloyd and his mother, Melinda Binkley, that Lloyd would not be admitted to United’s inpatient mental-health program and released Lloyd. The next night, Lloyd committed suicide. Binkley, acting as trustee, filed a medical-malpractice action against Allina Health System and its staff (collectively, Respondents) alleging that Respondents’ negligent failure to properly examine, evaluate, and provide services to Lloyd caused his death. Respondents filed a motion for summary judgment, arguing that they were entitled to immunity for their good-faith actions under the Minnesota Commitment and Treatment Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Respondents’ good-faith decision to deny Lloyd admission to the inpatient mental health unit is entitled to immunity; but (2) it is not clear that Respondents are entitled to summary judgment on all of Binkley’s claims. Remanded. View "Binkley v. Allina Health System" on Justia Law