Gallardo v. Marstiller

States are permitted to “seek reimbursement from settlement payments allocated for future medical care” under §1396k(a)(1)(A).

Petitioner was struck by a truck while exiting her school bus, leaving her in a vegetative state. Respondent’s medical expenses were paid for by Medicaid. States must seek reimbursement against third parties for Medicaid medical services rendered to the extent of the third party’s legal liability to the beneficiary and may pull portions of settlements allocated for “medical care.” 42 U.S.C §§ 1396a(a)(25)(A)–(B), 1396p(a)(1). Following a settlement, state law entitled Respondent to 37.5%, to presumptively recover funds spent for care. Fla. Stat. §§ 409.910(11)(f)(1), 409.910(17)(b). Petitioner brought suit in U.S. District Court, asking for a declaration that Respondent was violating the Medicaid Act by seeking settlement funds intended for future medical expenses. The District Court granted summary judgement; the Eleventh Circuit reversed. On appeal, the Supreme Court held that the State is permitted to “seek reimbursement from settlement payments allocated for future medical care” under §1396k(a)(1)(A). The Medicaid statute’s text does not specify past medical care like Petitioner suggests, but medical care generally. Id. Contextually, distinctions between “medical” and “nonmedical” payments are made, not between “past” and “future” medical payments. Congress’ intent behind the broad language used in §1396k(a)(1)(A) can be seen when contrasted against a statute in the same act which explicitly uses language Petitioner would read into it. See § 1396a(a)(25)(H). Affirmed.