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Law School Case Brief

Blum v. Yaretsky - 457 U.S. 991, 102 S. Ct. 2777 (1982)

Rule:

A state can be held responsible for a private decision only when it has exercised coercive power or has provided such significant encouragement, either overt or covert, that the choice must in law be deemed to be that of the state. Mere approval of or acquiescence in the initiatives of a private party is not sufficient to justify holding the state responsible for those initiatives under the terms of the Fourteenth AmendmentU.S. Const. amend. XIV.

Facts:

A nursing home's utilization review committee sought to transfer respondent patients to a lower level of care. The state social service officials affirmed the decision to discontinue benefits unless the patients accepted a transfer. The patients filed a lawsuit against the officials, seeking injunctive relief and damages. The district court approved a consent judgment and issued a permanent injunction against the officials. The circuit court affirmed. 

Issue:

Did the decision by a nursing home committee to transfer a Medicaid patient to another facility violate his Due Process rights under the Constitution?

Answer:

No

Conclusion:

After granting certiorari, the Court concluded that the patients had standing because of the threat of facility-initiated discharges or transfers to lower levels of care was sufficiently substantial. However, the Court held that the district court exceeded its authority in adjudicating the procedures governing transfers to higher levels of care because none of the patients had been threatened with such transfers.  State action was not established in the nursing homes' decisions to discharge or transfer Medicaid patients to lower levels of care, and therefore, a violation of rights secured by the Fourteenth Amendment was not proven, even though the nursing homes were extensively regulated by the state. Even though the state responded to the discharge or transfer decisions of the nursing homes by adjusting the patients' Medicaid benefits, the state required the completion of a certain form, the state imposed penalties on nursing homes that failed to discharge or transfer patients whose continued stay was inappropriate, the state subsidized the operating and capital costs of the facilities, the state paid the medical expenses of more than 90 per cent of the patients in the facilities, and the state licensed the facilities, the case involving decisions ultimately turned on medical judgments made by private parties according to professional standards not established by the state, and the nursing homes not performing a function that has traditionally been the exclusive prerogative of the state. The judgment was reversed.

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