Deceased Medicaid Applicant's Claim Against State Is Moot Despite Request for Retroactive Benefits

A U.S. court of appeals rules that a Medicaid applicant's claim against the state for an injunction declaring him eligible for benefits is mooted by the applicant’s death even though the claim includes three months' retroactive benefits. Pecha v. Lake (U.S. Ct. App., 10th Cir., No. 16-6143, July 25, 2017).

Alfred Pecha applied for Medicaid benefits in 2014. After the state denied his eligibility for benefits, Mr. Pecha sued the state in federal district court in Oklahoma. Mr. Pecha sought an injunction certifying that he was eligible for Medicaid and that the state had to pay three months' retroactive benefits. The state filed a motion to dismiss, arguing that the Eleventh Amendment barred the claim. The district court ruled that the Eleventh Amendment did not prevent payment of three months' retroactive benefits.

Mr. Pecha died, and the state filed a motion to dismiss, arguing that the case was moot. Mr. Pecha's attorney-in-fact countered that the district court could still order prospective relief that would permit the court to enter an order for the payment of retroactive Medicaid benefits. The district court dismissed this claim, and Mr. Pecha's attorney-in-fact appealed.

The U.S. Court of Appeals, 10th Circuit, affirms, holding that the case is moot. According to the court, because the claim for retroactive benefits is ancillary to the claim for prospective benefits, which is now moot, the claim for retroactive benefits "must fail for want of a prospective predicate."

For the full text of this decision, go to: https://www.ca10.uscourts.gov/opinions/16/16-6143_1.pdf

Did you know that the ElderLawAnswers database now contains summaries of more than 2,000 fully searchable elder law decisions dating back to 1993? To search the database, click here.