Gallardo v. Marstiller

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Supreme Court of the United States
Gallardo v. Marstiller
Term: 2021
Important Dates
Argued: January 10, 2022
Decided: June 6, 2022
Outcome
Affirmed
Vote
7-2
Majority
Clarence Thomas • Chief Justice John Roberts • Samuel Alito • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Dissenting
Sonia Sotomayor • Stephen Breyer

Gallardo v. Marstiller is a case that was decided by the Supreme Court of the United States on June 6, 2022, during the court's October 2021-2022 term. The case was argued before the court on January 10, 2022.

The court affirmed the decision of the U.S. Court of Appeals for the 11th Circuit in a 7-2 ruling, holding the "Medicaid Act permits a State to seek reimbursement from settlement payments allocated for future medical care."[1] Justice Clarence Thomas delivered the majority opinion of the court. Justice Sonia Sotomayor filed a dissenting opinion, joined by Justice Stephen Breyer. Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned tort claims and state Medicaid program reimbursement. Click here to learn more about the case's background.
  • The questions presented: "Whether the federal Medicaid Act provides for a state Medicaid program to recover reimbursement for Medicaid’s payment of a beneficiary’s past medical expenses by taking funds from the portion of the beneficiary’s tort recovery that compensates for future medical expenses."[2]
  • The outcome: The court affirmed the decision of the U.S. Court of Appeals for the 11th Circuit in a 7-2 ruling, holding the "Medicaid Act permits a State to seek reimbursement from settlement payments allocated for future medical care."[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the 11th Circuit.[3] To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    • June 6, 2022: The U.S. Supreme Court affirmed the U.S. Court of Appeals for the 11th Circuit's ruling.
    • January 10, 2022: The U.S. Supreme Court heard oral argument.
    • July 2, 2021: The U.S. Supreme Court agreed to hear the case.
    • March 9, 2021: Parents and co-guardians Pilar Vassallo and Walter Gallardo appealed to the U.S. Supreme Court on their daughter Gianinna Gallardo's behalf.
    • October 20, 2020: The 11th Circuit denied the petition for rehearing en banc.

    Background

    Factual and procedural background

    In November 2008, 13-year-old student Gianinna Gallardo was struck by a truck after exiting her school bus. As a result of her injuries, Gallardo remains in a permanent vegetative state. Florida’s state Medicaid program paid $862,688.77 toward the medical expenses. Gallardo's parents filed a civil suit in state court against the truck owner and driver, and the school board. The suit was settled with court approval for $800,000 awarded to Gallardo's parents, allocated to pay for both past and future medical care. Florida's Medicaid agency was authorized to intervene in the suit and/or file its own suit to seek reimbursement from the third party but did not do so. The agency filed a lien against Gallardo for $862,688.77. According to the state's statutory formula, the agency was entitled to $300,000 of the settlement money. Gallardo contested the lien and deposited the $300,000 into an interest-bearing trust for the state's benefit and filed a petition with the Florida Agency for Health Care Administration. The administrative hearing was temporarily put on hold while the proceedings in federal court progressed.[2][3][4][5]

    In 2017, Gallardo sought a federal court determination of her rights under the Medicaid Act. The district court issued a declaratory judgment that the Medicaid Act prohibited the state from seeking reimbursement of past payments from portions of the settlement award allocated for future medical expenses and enjoined, or halted, the state from enforcing the Florida statute allowing such reimbursement.[2]

    On June 26, 2020, the U.S. Court of Appeals for the 11th Circuit reversed the district court's judgment. On July 17, 2020, Gallardo filed a petition for a rehearing en banc. The 11th Circuit denied rehearing on October 20, 2020, holding that the Medicaid Act authorized a Florida statute permitting the state to file a lien over settlement money allocated for future medical expenses.[2][3]

    The court also noted that its ruling conflicted with the Florida Supreme Court's ruling in Giraldo v. Agency for Health Care Admin. (2018):[3]

    “ Although it is unfortunate that our interpretation of federal law conflicts with the Florida Supreme Court's interpretation of federal law and presents a forum shopping possibility, we cannot for that reason endorse an incorrect interpretation of federal law. ...[6] ”



    In the petition to the U.S. Supreme Court, filed on March 9, 2021, Gallardo's counsel addressed the split:[2]

    “ But the conflict on this issue runs much deeper: One state court of last resort aligns with the Eleventh Circuit, and three align with the Florida Supreme Court. Other lower courts—both state and federal—are also split. ...[6] ”



    On July 2, 2021, the U.S. Supreme Court agreed to hear the case.

    Parties involved

    • Petitioner: Gianinna Gallardo, an incapacitated person, by and through her parents and co-guardians Pilar Vassallo and Walter Gallardo[2]
    • Respondent: Simone Marstiller, in her official capacity as Secretary of the Florida Agency for Health Care Administration[2]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether the federal Medicaid Act provides for a state Medicaid program to recover reimbursement for Medicaid’s payment of a beneficiary’s past medical expenses by taking funds from the portion of the beneficiary’s tort recovery that compensates for future medical expenses.[6] ”

    Oral argument

    Audio

    Audio of oral argument:[7]



    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 7-2 opinion, the court affirmed the judgment of the 11th Circuit Court of Appeals, holding the "Medicaid Act permits a State to seek reimbursement from settlement payments allocated for future medical care." Justice Thomas delivered the opinion of the court. Justice Sotomayor dissented, joined by Justice Breyer.[1]

    Opinion

    In the court's majority opinion, Justice Thomas wrote:[1]

    “

    The question presented is whether [42 U. S. C. §1396k(a)(1)(A)] permits a State to seek reimbursement from settlement payments allocated for future medical care. We conclude that it does. ...

    Gallardo argues that the Eleventh Circuit erred by permitting Florida to seek reimbursement for medical expenses from settlement amounts representing payment for future medical care. According to Gallardo, the Medicaid Act’s anti-lien provision in §1396p forecloses recovery from settlement amounts other than those allocated for past medical care paid for by Medicaid. Thus, Gallardo concludes, the anti-lien provision preempts any state law that permits additional recovery.

    We disagree. Under §1396k(a)(1)(A), Florida may seek reimbursement from settlement amounts representing “payment for medical care,” past or future. Thus, because Florida’s assignment statute “is expressly authorized by the terms of . . . [§]1396k(a),” it falls squarely within the “exception to the anti-lien provision” that this Court has recognized.[6]

    		”
    —Justice Thomas

    Dissenting opinion

    Justice Sotomayor filed a dissenting opinion, joined by Justice Breyer.

    In her dissent, Justice Sotomayor wrote:[1]

    “

    This statutory structure recognizes that it would be “‘fundamentally unjust’” for a state agency to “‘share in damages for which it has provided no compensation.’” ... Today, however, the Court permits exactly that. It holds that States may reimburse themselves for medical care furnished on behalf of a beneficiary not only from the portions of the beneficiary’s settlement representing compensation for Medicaid-furnished care, but also from settlement funds that compensate the Medicaid beneficiary for future medical care for which Medicaid has not paid and might never pay. The Court does so by reading one statutory provision in isolation while giving short shrift to the statutory context, the relationships between the provisions at issue, and the framework set forth in precedent. The Court’s holding is inconsistent with the structure of the Medicaid program and will cause needless unfairness and disruption. I respectfully dissent. [6]

    		”
    —Justice Sotomayor

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]

    The court agreed to hear 68 cases during its 2021-2022 term.[10] Four cases were dismissed and one case was removed from the argument calendar.[11]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 Supreme Court of the United States, Gallardo v. Marstiller, decided June 6, 2022
    2. ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 U.S. Supreme Court, "Gallardo v. Marstiller: On Petition for Writ of Certiorari to the United States Court of Appeals for the Eleventh Circuit," filed March 9, 2021
    3. ↑ 3.0 3.1 3.2 3.3 United States Court of Appeals for the 11th Circuit, Gallardo v. Dudek, decided October 20, 2020
    4. ↑ SCOTUSblog, "Justices add one religious-rights case to docket but turn down another," July 2, 2021
    5. ↑ SCOTUSblog, "Medicaid, Medicare and House representation for the District of Columbia," April 16, 2021
    6. ↑ 6.0 6.1 6.2 6.3 6.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued January 10, 2022
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued January 10, 2022
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    10. ↑ Consolidated cases are counted as one case for purposes of this number.
    11. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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