Medicaid Applicant's Claim in Federal Court Is Dismissed Due to Younger Abstention

Excerpt from Elder Law Answers: (click for entire article)

In a case pursued by a Missouri ElderLawAnswers member attorney, a U.S. court of appeals holds that a Medicaid applicant's claim against the state in federal court must be dismissed due to Younger abstention because the applicant did not exhaust her administrative remedies. Hudson v. Campbell (8th Cir., No. 10–3025, Dec. 15, 2011).

 Greta Hudson applied for Medicaid in Missouri, but the state denied her benefits on the grounds that she had transferred property. She appealed the denial and requested a hearing. While the hearing was pending Ms. Hudson received a notice saying the state was relying on a different reason for denying Ms. Hudson benefits. The hearing officer informed her that he did not have jurisdiction to hear an appeal on the withdrawn reason for denial and suggested she file a second hearing request.

 Instead of requesting a second hearing, Ms. Hudson filed a claim in federal court. The trial court determined it needed to abstain based on the U.S. Supreme Court's decision in Younger v. Harris, 401 U.S. 37 (1971) and dismissed Ms. Hudson's claim. She appealed, arguing that abstention is inapplicable when the administrative proceedings are remedial rather than coercive.