United States Ninth Circuit

The district court's decisions in four cases are reversed and remanded, and the preliminary injunctions prohibiting the California Department of Health Care Services and its Director from implementing Medi-Cal reimbursement rate reductions authorized by the California legislature and approved by the Secretary of the Department of Health and Human Services are vacated, where: 1) the Secretary's approval of California's requested reimbursement rates, including her permissible view that prior to reducing rates states need not follow any specific procedural steps, was entitled to Chevron deference; 2) the Secretary's approval complied with the Administrative Procedures Act; 3) plaintiffs were unlikely to succeed on the merits of their Supremacy Clause claims against the California Director because, even assuming that the Supremacy Clause provides a private right of action, the Secretary had reasonably determined that the State’s reimbursement rates complied with 42 U.S.C. section 1396a(a)(30)(A); and 4) none of the plaintiffs had a viable takings claim because Medicaid, as a voluntary program, does not create property rights. (Superseding opinion)

Appellate Information

• Decided 05/24/2013
• Published 05/24/2013

Judges

• TROTT

Court

• United States Ninth Circuit

Counsel