Justia U.S. 10th Circuit Court of Appeals Opinion Summaries

The case involves a congressional program that awards grants for family-planning projects, with the Department of Health and Human Services (HHS) setting eligibility requirements. Oklahoma, a grant recipient, expressed concerns about these requirements, citing state laws prohibiting counseling and referrals for abortions. HHS proposed that Oklahoma provide neutral information about family-planning options, including abortion, through a national call-in number. Oklahoma rejected this proposal, leading HHS to terminate the grant. Oklahoma challenged the termination and sought a preliminary injunction.The United States District Court for the Western District of Oklahoma denied Oklahoma's motion for a preliminary injunction, determining that Oklahoma was unlikely to succeed on the merits of its claims. Oklahoma then appealed the decision.The United States Court of Appeals for the Tenth Circuit reviewed the case. Oklahoma argued that it would likely succeed on the merits for three reasons: (1) Congress's spending power did not allow it to delegate eligibility requirements to HHS, (2) HHS's requirements violated the Weldon Amendment, and (3) HHS acted arbitrarily and capriciously. The Tenth Circuit rejected these arguments, holding that:1. The spending power allowed Congress to delegate eligibility requirements to HHS, and Title X was unambiguous in conditioning eligibility on satisfaction of HHS's requirements. 2. The Weldon Amendment, which prohibits discrimination against health-care entities for declining to provide referrals for abortions, was not violated because HHS's proposal to use a national call-in number did not constitute a referral for the purpose of an abortion. 3. HHS did not act arbitrarily and capriciously in terminating Oklahoma's grant, as the eligibility requirements fell within HHS's statutory authority, and Oklahoma did not demonstrate a likely violation of HHS's regulations.The Tenth Circuit affirmed the district court's denial of the preliminary injunction, concluding that Oklahoma had not shown a likelihood of success on the merits of its claims. View "State of Oklahoma v. HHS" on Justia Law

The case involves Robert Lewis Dear Jr., who was charged with attacking a Planned Parenthood clinic in Colorado Springs, Colorado, in 2015. Dear was found incompetent to stand trial due to a diagnosis of delusional disorder, persecutory type. Despite being found incompetent multiple times, the district court ordered Dear to be involuntarily medicated in an attempt to restore his competency, following a motion by the government.Previously, Dear had been in state custody for about four years, during which he was continually found incompetent to stand trial. In December 2019, the federal government indicted Dear on 68 counts. The government moved for a competency evaluation under 18 U.S.C. § 4241, which led to Dear being transferred to the United States Medical Center for Federal Prisoners in Springfield, Missouri. There, a psychiatrist evaluated Dear and determined that although he remained incompetent due to his delusional disorder, he was substantially likely to be restored to competency through the administration of antipsychotics.The United States Court of Appeals for the Tenth Circuit affirmed the district court's order for involuntary medication. The court held that the district court made sufficiently detailed factual findings and that those findings were not clearly erroneous. The court placed greater weight on the government’s experts due to their extensive experience restoring competency and their personal experience observing and interacting with Dear. View "United States v. Dear" on Justia Law

A California-based psychologist, Dr. Rick Q. Wilson, was investigated by the Drug Enforcement Administration (DEA) for potential violations of the Controlled Substances Act. The DEA issued an administrative subpoena to obtain Wilson's medical, prescription, and billing records. Wilson challenged the subpoena on statutory, constitutional, and privacy grounds.The district court initially dismissed the United States' petition to enforce the subpoena, finding it violated the Health Insurance Portability and Accountability Act (HIPAA) and the Fourth Amendment. However, upon reconsideration, the court granted the United States' motion to amend the petition and enforce a narrowed version of the subpoena.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court found that the modified subpoena complied with HIPAA, was not unreasonably burdensome under the Fourth Amendment, and did not violate Wilson's Fifth Amendment privilege against self-incrimination due to the required-records exception. The court held that the subpoena was issued within the DEA's authority, was relevant to the DEA's investigation, and was not unreasonably broad or burdensome. The court also found that the records requested fell within the required-records exception to the Fifth Amendment's privilege against self-incrimination. View "United States v. Wilson" on Justia Law

In this case, the United States Court of Appeals for the Tenth Circuit dealt with the appeal of Youlian Zhong, who contested her mandatory minimum sentences for crimes related to her participation in a conspiracy to manufacture and distribute large quantities of marijuana. Zhong argued that the district court erred in finding that she did not qualify for the statutory safety valve for mandatory minimum sentences.Zhong and her husband, Housheng Xian, were found guilty of conspiring to grow more than 1,500 marijuana plants in their residence, intending to process and sell the marijuana. They were convicted on three counts: conspiring to manufacture and possess with the intent to distribute 1,000 and more marijuana plants, manufacturing and possessing with intent to distribute 1,000 or more marijuana plants, and using and maintaining their house for the purpose of manufacturing and distributing marijuana.Before sentencing, Zhong and Xian requested a non-guideline sentence of time served plus five years of supervised release, arguing that they met the requirements of the safety valve provisions. However, the court found that they did not provide all necessary information to the government, particularly regarding their mens rea, or intent, for the crimes for which they were convicted.On appeal, the Tenth Circuit affirmed the lower court's decision. The appeals court held that a defendant must provide the government with information sufficient to prove the mens rea required for the crimes of conviction to meet the requirement of providing “all information and evidence” concerning the offense for the safety valve provision to apply. The court concluded that Zhong did not provide sufficient information about her intent to commit the crimes for which she was convicted, and thus, did not meet her burden to prove that she qualified for safety-valve relief. View "United States v. Zhong" on Justia Law

The United States Court of Appeals for the Tenth Circuit reviewed the dismissal of a case involving Charles Cline, who was terminated by Clinical Perfusion Systems, Inc. after a medical emergency led to an extended hospital stay. Cline brought forward disability discrimination claims under the Rehabilitation Act, the Affordable Care Act (ACA), and the Oklahoma AntiDiscrimination Act (OADA); and age discrimination claims under the OADA. The court concluded that Cline was unable to establish a disability discrimination claim as he failed to plausibly allege that he could perform his job functions with a reasonable accommodation by his employer. The court also disagreed with the district court's dismissal of Cline's age discrimination claim, arguing that Cline had sufficiently alleged that age was a but-for cause of his termination. Therefore, the court affirmed the dismissal of Cline's disability discrimination claims, reversed the dismissal of his age discrimination claim, and remanded the case for further proceedings. View "Cline v. Clinical Perfusion Systems" on Justia Law

Plaintiff-Appellant E.W. was a participant in an employer-sponsored health insurance plan governed by the Employee Retirement Income Security Act of 1974 (“ERISA”). E.W.’s daughter, Plaintiff-Appellant I.W., was a beneficiary of E.W.’s plan. From September 2016 through December 2017, I.W. received treatment in connection with mental health challenges and an eating disorder at Uinta Academy (“Uinta”), an adolescent residential treatment center in Utah. In January 2017, Defendants-Appellees Health Net Insurance Company and Health Net of Arizona, Inc. began covering I.W.’s treatment under E.W.’s ERISA plan (the “Plan”). Effective February 23, 2017, Health Net determined I.W.’s care at Uinta was no longer medically necessary, and it denied coverage from that day forward. In assessing whether to discontinue coverage, Health Net applied the McKesson InterQual Behavioral Health 2016.3 Child and Adolescent Psychiatry Criteria. Health Net determined I.W. did not satisfy the InterQual Criteria within the relevant period and notified Plaintiffs in a letter dated March 1, 2017. Plaintiffs allegedly did not receive Health Net’s March 2017 denial letter, and I.W. remained at Uinta until December 2017, when she was formally discharged. After receiving notice in May 2018 that Health Net had denied coverage effective February 23, 2017, Plaintiffs appealed the decision. Health Net again determined I.W. did not satisfy the InterQual Criteria during the relevant period and upheld its initial denial. Plaintiffs then appealed to an external reviewer, which upheld the decision to deny coverage. Health Net moved to dismiss plaintiffs' legal claims under ERISA and the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (“MHPAEA”). The district court denied Plaintiffs’ motion and granted summary judgment to Health Net. After review, the Tenth Circuit affirmed the district court’s decision granting summary judgment to Health Net on Plaintiffs’ ERISA claim; the Court reversed the finding Plaintiffs failed to state a claim under MHPAEA; and the case was remanded for further proceedings. View "W., et al. v. Health Net Life Insurance Company, et al." on Justia Law

In 2019, the Oklahoma legislature unanimously passed the Patient’s Right to Pharmacy Choice Act. In response to the Act’s passage, the Pharmaceutical Care Management Association (PCMA), a trade association representing PBMs, sued to invalidate the Act, alleging that the Employee Retirement Income Security Act of 1974 (ERISA), and Medicare Part D, preempted the Act. The district court ruled that ERISA did not preempt the Act but that Medicare Part D preempted six of the thirteen challenged provisions. PCMA appealed the court’s ERISA ruling on four provisions of the Act and the court’s Medicare Part D ruling on one provision. After its review, the Tenth Circuit determined ERISA and Medicare Part D preempted the four challenged provisions, and therefore reversed. View "Pharmaceutical Care v. Mulready, et al." on Justia Law

Plaintiffs David P. and his daughter L.P. sought to recover health care benefits under a medical plan David P. obtained through his employer. The district court awarded Plaintiffs benefits, determining that the manner in which Defendants processed Plaintiffs’ claims for coverage violated ERISA. The Tenth Circuit Court of Appeals agreed: Defendants’ deficient claims processing circumvented the dialogue ERISA mandates between plan participants claiming benefits and the plan administrators processing those benefits claims. The Court disagreed, however, with the district court as to the appropriate remedy for the violations of ERISA’s claims-processing requirements at issue here. "Rather than outright granting Plaintiffs their claimed benefits, we conclude, instead, that Plaintiffs’ claims for benefits should be remanded to Defendants for proper consideration." The case was remanded to the district court with directions to remand Plaintiffs’ benefits claims to Defendants. View "P., et al. v. United Healthcare Insurance, et al." on Justia Law

Middle schooler A.K. struggled with suicidal ideation for many years and attempted suicide numerous times, resulting in frequent emergency room visits and in-patient hospitalizations. A.K.’s physicians strongly recommended she enroll in a residential treatment facility to build the skills necessary to stabilize. Despite these recommendations and extensive evidence in the medical record, United Behavioral Health (“United”) denied coverage for A.K.’s stay at a residential treatment facility beyond an initial three month period. Her parents appealed United’s denial numerous times, requesting further clarification, and providing extensive medical evidence, yet United only replied with conclusory statements that did not address the evidence provided. As a result, A.K.’s parents brought this lawsuit contending United violated its fiduciary duties by failing to provide a “full and fair review” of their claim for medical benefits. Both sides moved for summary judgment, and the district court ruled against United. The issue this case presented for the Tenth Circuit's review was whether United arbitrarily and capriciously denied A.K. medical benefits and whether the district court abused its discretion in awarding A.K. benefits rather than remanding to United for further review. The Court ultimately concluded United did act arbitrarily and capriciously in not adequately engaging with the opinions of A.K.’s physicians and in not providing its reasoning for denials to A.K.’s parents. The Court also concluded the district court did not abuse its discretion by awarding A.K. benefits outright. View "D.K., et al. v. United Behavioral Health, et al." on Justia Law

Michelle Caddell died from cervical cancer while in custody as a pretrial detainee in the Tulsa County Jail. Yolanda Lucas, as special administrator of decedent Caddell’s estate, initiated this case under 42 U.S.C. § 1983 bringing claims of deliberate indifference in violation of the Eighth and Fourteenth Amendments against Dr. Gary Myers and against Turn Key Health Clinics, LLC (“Turn Key”) and Sheriff Vic Regalado in his official capacity through municipal liability, violations of the Equal Protection clause against Turn Key and Sheriff Regalado, and negligence and wrongful death under Oklahoma state law against Dr. Myers and Turn Key. The three Defendants individually moved to dismiss all claims and the district court granted the motions. On appeal, Plaintiff challenged the district court’s determinations that she failed to plausibly allege: (1) deliberate indifference to serious medical needs against Dr. Myers; (2) municipal liability against Turn Key and Sheriff Regalado; and (3) violation of the Equal Protection clause against Turn Key and Sheriff Regalado. She also challenged the finding that Dr. Myers and Turn Key were entitled to immunity for the state law claims under the Oklahoma Governmental Tort Claims Act (“OGTCA”). The Tenth Circuit found it would need to determine the OGTCA's applicability to private corporations (and their employees) that contract with the state to provide medical services at the summary judgment stage if the factual record is sufficiently developed and the facts are uncontroverted. Accordingly, the Court reversed as premature the district court’s decision that Turn Key and Dr. Myers were immune under the OGTCA. The Court affirmed in all other respects. View "Lucas v. Turn Key Health Clinics, et al." on Justia Law