Medicaid Claim Dismissed by Federal Court Due to Younger Abstention

The state of Missouri denied Medicaid benefits to Greta Hudson, claiming the denial was due to the fact that Hudson had transferred property. Hudson appealed, and while the hearing was pending, was informed that the state denied her benefits for a different reason. The hearing officer stated he did not have jurisdiction to hear the appeal on the withdrawn reason for denial.

Hudson filed a claim in federal court and the trial court opted to abstain based on the U.S. Supreme Court’s decision in Younger v. Harris, 401 U.S. 37 (1971). The trial court dismissed the claim and Hudson appealed, arguing that abstention is inapplicable when the administrative proceedings are remedial.

In Hudson v. Campbell (8th Cir., No. 10–3025, Dec. 15, 2011), the U.S. Court of Appeals for the Eighth circuit held that abstention is appropriate and held that the federal court lacked jurisdiction.

See Medicaid Applicant’s Claim in Federal Court is Dismissed Due to Younger Abstention, ElderLawAnswers, Dec. 17, 2011.