Justia Maine Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed in part and vacated in part the judgment of the superior court affirming the decision of the Commissioner of the Department of Health and Human Services (Department) accepting the recommendation of an administrative presiding officer that the Department correctly established and maintained a recoupment claim for $116,852 against Appellant, an oral surgeon, holding that remand was required as to one aspect of the Department's decision.Appellant was a MaineCare provider whose practice was based in Auburn. After Appellant retired, the Department issued a notice of violation, alleging that Appellant had been overpaid. After an administrative hearing, the Department reduced its claim to $116,852. The presiding officer upheld the Department's recoupment claim. The Commissioner adopted the presiding officer's recommended decision in full. The Supreme Judicial Court reversed in part and remanded the case, holding (1) because the Department failed to explain its decision imposing the maximum allowable penalties for Appellant's failure properly to document time spent with patients following his administration of anesthesia, the Court was unable to determine whether the Department properly exercised its discretion; and (2) Appellant was not entitled to relief on his remaining allegations of error. View "Palian v. Department of Health and Human Services" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court vacating a Department of Health and Human Services hearing officer's decision requiring AngleZ Behavioral Health Services to pay $392,603.31 in MaineCare reimbursements because of billing errors, holding that the superior court erred by finding that the Department did not submit proper evidence in support of some of its recoupment claims.After auditing the claims submitted by AngleZ between February 13, 2013 and July 20, 2013 The Department issued a notice of violation applying an error rate to all of AngleZ's claims during that time period. The Department ultimately sought a total recoupment of $392,603.31. A hearing officer concluded that the Department was correct in seeking 392,603.31 in recoupment, and the Department's acting commissioner adopted the recommendation. The superior court vacated the Commissioner's decision, concluding that the hearing officer's decision was not supported by substantial evidence. The Supreme Judicial Court vacated the superior court's judgment, holding that the hearing officer's decision was supported by substantial evidence and was neither arbitrary nor capricious. View "AngleZ Behavioral Health Services v. Department of Health and Human Services" on Justia Law

The Supreme Judicial Court dismissed the appeal brought by the Department of Health and Human Services (Department) from a partial judgment entered in the Business and Consumer Docket mandating the implementation of one provision of the citizen initiative expanding Medicaid coverage.The initiating petition in this case requested numerous forms of relief. The superior court addressed only one component of the requested relief due to ripeness issues. The Supreme Judicial Court decided that it must dismiss this appeal as interlocutory because the petition was not disposed of in its entirety and no exception to the final judgment rule existed. View "Maine Equal Justice Partners v. Commissioner, Department of Health & Human Services" on Justia Law

Me. Rev. Stat. 39-A, 221 entitles an employer to a credit for workers’ compensation benefits previously paid for the same liability period when the employee was also receiving Social Security retirement benefits.Plaintiff was paid total incapacity workers’ compensation benefits by his employer, Interstate Brands International, after he sustained injuries in an initial workplace accident. For three years, Plaintiff collected Social Security retirement benefits while receiving the full amount of the workers’ compensation benefits. When Interstate learned that Plaintiff was receiving Social Security benefits, it sought a credit against the ongoing incapacity payments pursuant to section 221. A hearing officer determined that Interstate was entitled to a credit of nearly $25,000. The Workers’ Compensation Appellate Division vacated the decree, concluding that section 221 does not allow a reduction based on incapacity overpayments made in the past. The Supreme Judicial Court vacated the Appellate Division’s decision, holding that Interstate was entitled to a credit for incapacity benefit overpayments made to Plaintiff during the same period when he received Social Security retirement benefits. View "Urrutia v. Interstate Brands International" on Justia Law

Me. Rev. Stat. 39-A, 221 entitles an employer to a credit for workers’ compensation benefits previously paid for the same liability period when the employee was also receiving Social Security retirement benefits.Plaintiff was paid total incapacity workers’ compensation benefits by his employer, Interstate Brands International, after he sustained injuries in an initial workplace accident. For three years, Plaintiff collected Social Security retirement benefits while receiving the full amount of the workers’ compensation benefits. When Interstate learned that Plaintiff was receiving Social Security benefits, it sought a credit against the ongoing incapacity payments pursuant to section 221. A hearing officer determined that Interstate was entitled to a credit of nearly $25,000. The Workers’ Compensation Appellate Division vacated the decree, concluding that section 221 does not allow a reduction based on incapacity overpayments made in the past. The Supreme Judicial Court vacated the Appellate Division’s decision, holding that Interstate was entitled to a credit for incapacity benefit overpayments made to Plaintiff during the same period when he received Social Security retirement benefits. View "Urrutia v. Interstate Brands International" on Justia Law

The Supreme Judicial Court vacated the judgment entered by the superior court upholding the final agency decision of the Department of Health and Human Services denying Appellant’s application for food supplement benefits.The Department denied Appellant’s application for food benefits based on language in the public law not present within the statutory text. The language at issue contained a fiscal limitation of $261,384 and a temporal limitation - June 30, 2015 - on the availability of funding for benefits for persons otherwise eligible under Me. Rev. Stat. 22, 3104-A(1)(D) (Paragraph D). The Supreme Judicial Court concluded that the Legislature intended for Paragraph D to be a permanent exception to the general ineligibility of noncitizen for food assistance under section 3104-(A)(1) and that the temporal and fiscal limitations contained in P.L 2013, ch. 368, section 00-14 applied only to the fiscal years ending June 30, 2013, June 30-2015, and June 30, 2015 and not beyond June 30, 2015. View "Manirakiza v. Department of Health & Human Services" on Justia Law

John F. Murphy Homes, Inc. operates a private school that offers medical services that are paid for by MaineCare, a State Medicaid program. The State pays one-third of costs for MaineCare, a contribution commonly referred to as the Seed. In 2013, Murphy Homes filed a complaint that, as construed by the trial court, stated claims for breach of contract, quantum meruit, and an equitable claim for unjust enrichment or equitable estoppel, alleging that it was owed $7.5 million for Seed payments not paid between 2001 and 2011. The trial court granted summary judgment for the State on all claims. The Supreme Judicial Court affirmed, holding (1) the breach of contract and quantum meruit claims were not legally viable; and (2) Murphy Homes failed to allege facts to generate a trial worthy issue of fact on the reliance element of its equitable estoppel claim. View "John F. Murphy Homes, Inc. v. State" on Justia Law

Sharon and Nathan Weston divorced in 2005 pursuant to a divorce decree stating that Nathan would provide child support for the couple's adult disabled son, Alex, as long as Alex was unemancipated, which was defined as domiciled with Sharon and "principally dependent upon Sharon for support." In 2008, Alex and Sharon began participating in a program that provided Sharon about $30,000 annually. The district court granted Nathan's subsequent motion to modify child support, concluding that Alex was emancipated pursuant to the terms of the divorce decree because Alex was financially supported by the state and the Social Security Administration. The Supreme Court vacated the order terminating Nathan's child support obligation, holding that notwithstanding the government benefits he received, Alex was principally dependent on Sharon's financial contribution, and therefore, Alex was not emancipated. View "Weston v. Weston" on Justia Law

Mrs. T. was the mother of C.T., a fifteen-year-old boy with severe disabilities. At issue in this case was C.T.'s eligibility for the Department of Health and Human Services' home and community-based waiver program. C.T. was approved for the waiver program but was not receiving services under the waiver when the Department instituted a new regulation that closed the program to children but grandfathered children who were already receiving services. Mrs. T. subsequently filed a grievance with the Department seeking to have C.T. declared waiver-eligible. The Commissioner of the Department accepted the recommendation of an administrative hearing officer that denied the grievance. The superior court affirmed. Mrs. T. appealed, contending that the Department was equitably estopped from denying services because she reasonably relied to her detriment on misinformation she received that C.T. was eligible. The Supreme Court affirmed, holding that because Mrs. T. did not meet her burden to prove that her reliance on the misinformation given to her by the Department caused any detriment to C.T., the hearing officer did not err in finding that the Department was not equitably estopped from declaring C.T. ineligible for a waiver. View "Mrs. T. v. Dep't of Health & Human Servs." on Justia Law

Robert and Candy Smith are the parents of a developmentally disabled child, Justan. In April, 2009, Mrs. Smith filed an appointment petition in the Probate Court to become Justan's sole guardian and conservator. The court set forth a schedule where visitation rights were divided equally between the parents. Mr. Smith intentionally prevented his wife from having her scheduled visits with Justan in June, 2009. Mrs. Smith subsequently filed a motion for contempt. The Probate Court held hearings both on the guardianship petition and Mrs. Smithâs motion for contempt. Over her ex-husband's objection, the court admitted testimonial reports from the guardian ad litem. As a result, the Probate Court entered a judgment appointing the former Mrs. Candy Smith and Mr. Smithâs new wife, Christine, as co-guardians of Justan. Christine was to become Justanâs sole conservator. The Probate Court erroneously ordered, as part of the judgment, that at least $200 per month from Justanâs social security insurance benefits be deposited into a bank account that named as account holders Justan, Christine and the former Mrs. Smith. Mr. Smiith filed a motion for findings and conclusions of law. The court complied and issued an amended judgment containing minor changes. Mr. Smith appealed. The Supreme Court found that the portion of the Lower Courtâs decision pertaining to the fore-mentioned $200 monthly deposit conflicted with Federal statues and regulations. Mr. Smith was vested with a discretionary authority to execute Justin's social security insurance monies. The Court vacated this portion of the Probate Courtâs judgment and affirmed the remainder.