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Keywords

defendantjurisdictioninjunctionappeal
defendantjurisdictiondamagesinjunctionappealwill

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National Kidney Patients Ass’n v. Sullivan, 958 F.2d 1127, 294 U.S.App.D.C. 269, 60 USLW 2593, 23 Fed.R.Serv.3d 1072, 36 Soc.Sec.Rep.Serv. 685, Med & Med GD (CCH) P 40,057

Facts

For over 13 months, HHS made payments to Home Intensive Care, Inc. (HIC) under a preliminary injunction issued by the district court. This injunction was modified and vacated as moot due to congressional action, which capped Method II payments at the Method I level. HHS sought to recover approximately $15 million in overpayments made to HIC during the injunction period, arguing that the injunction was improvidently granted.

For slightly over 13 months the Department of Health and Human Services made payments to Home Intensive Care, Inc. (“HIC”) under a preliminary injunction issued by the district court.

Issue

Did the district court have jurisdiction to issue the preliminary injunction preventing HHS from reducing reimbursement for home dialysis treatment, and is HHS entitled to recoup overpayments made under that injunction?

The Court of Appeals, Stephen F. Williams, Circuit Judge, held that: (1) District Court lacked jurisdiction to preliminarily enjoin Department of Health and Human Services, and (2) Department could apply its recoupment procedures in seeking refund of overpayments made to health care services provider under injunction.

Rule

The court applied the principle that a valid injunction must be based on jurisdiction, and if the injunction is found to be wrongful, the defendant is presumptively entitled to recover on the injunction bond.

As to damages, a defendant injured by a wrongfully issued preliminary injunction is presumptively entitled to recovery on the injunction bond.

Analysis

The court concluded that the district court lacked jurisdiction to issue the preliminary injunction, as the claims made by HIC were not properly presented to the Secretary's delegate. Consequently, the court determined that HHS was entitled to recover the amounts paid under the injunction, as the injunction was deemed wrongful.

Accordingly, we must consider whether the district court had jurisdiction. As we conclude that it did not, we need not—indeed, cannot—address the merits of HIC's claim.

Conclusion

The Court of Appeals reversed the district court's decision, allowing HHS to recoup the overpayments made to HIC and to recover on the injunction bond.

We agree, and reverse the order of the district court.

Who won?

The government prevailed in the case because the Court of Appeals found that the district court lacked jurisdiction to issue the injunction and that HHS was entitled to recoup the overpayments.

We think, however, that the October 1986 amendment makes the Eldridge–Ringer line of authority the sole determinant of jurisdiction for Medicare claims, both parts A and B.

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