Law School Case Brief
Alexander v. Choate - 469 U.S. 287, 105 S. Ct. 712 (1985)
Recipients of federal funds who provide health services cannot provide a qualified handicapped person with benefits or services that are not as effective, as defined in 45 C.F.R. § 84.4(b), as the benefits or services provided to others under 45 C.F.R. § 84.52(a)(3) (1984). The regulations also prohibit a recipient of federal funding from adopting criteria or methods of administration that have the purpose or effect of defeating or substantially impairing accomplishment of the objectives of the recipient's program with respect to the handicapped under 45 C.F.R. § 84.4(b)(4)(ii) (1984).
Faced with Medicaid costs beyond its budget, the state of Tennessee proposed to reduce from 20 to 14 the number of annual inpatient hospital days that state Medicaid would pay hospitals on behalf of a Medicaid recipient. Before the reduction took effect, respondent Medicaid recipients brought a class action in Federal District Court for declaratory and injunctive relief. Respondents alleged that the proposed 14-day limitation would have a disproportionate effect on the handicapped and therefore was discriminatory in violation of § 504 of the Rehabilitation Act of 1973, 29 U.S.C.S. § 794, which provides that no otherwise qualified handicapped person shall, solely by reason of his handicap, be subjected to discrimination under any program receiving federal financial assistance; moreover, any annual limitation on inpatient coverage would disadvantage the handicapped disproportionately in violation of § 504. The District Court dismissed the complaint on the ground that the 14-day limitation was not the type of discrimination that § 504 was intended to proscribe. The United States Court of Appeals for the Sixth Circuit reversed, concluding that respondents had established a prima facie case of a § 504 violation because both the 14-day and any annual limitation on inpatient coverage would disproportionately affect the handicapped. The United States Supreme Court granted the petition for certiorari review.
Did the appellate court err in holding that respondents had established a prima facie violation of § 504 of the Rehabilitation Act of 1974?
The appellate court erred in holding that respondents had established a prima facie violation of § 504. The effect upon the handicapped of the reduction was not cognizable under the statute or its implementing regulations. The 14-day rule was neutral on its face, was not alleged to rest on a discriminatory motive, and did not deny the handicapped access to or exclude them from the state's package of Medicaid services. The state made the same benefit equally accessible to both handicapped and nonhandicapped persons. The state was not required to provide the handicapped with more coverage than the nonhandicapped, or to modify program by abandoning reliance on annual limits on in-patient coverage.
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