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Keywords

lawsuitappealhearingregulation

statuteappealhearingregulationconstitutional lawrespondent

Related Cases

O’Bannon v. Town Court Nursing Center, 447 U.S. 773, 100 S.Ct. 2467, 65 L.Ed.2d 506

Facts

Town Court Nursing Center, a nursing home in Philadelphia, was certified by the Department of Health, Education, and Welfare (HEW) to provide nursing care under Medicare and Medicaid. In May 1977, HEW notified Town Court that it no longer met the necessary standards for certification, leading to the termination of its provider agreements. Town Court and several patients filed a lawsuit claiming they were entitled to a hearing before the termination of Medicaid payments, arguing that the loss of benefits would cause irreparable harm.

After the Department of Health, Education, and Welfare (HEW) and the Pennsylvania Department of Public Welfare (DPW) had revoked the authority of Town Court Nursing Center (a nursing home) to provide elderly residents of the home with nursing care at government expense under Medicare and Medicaid provider agreements, the home and several of its patients (respondents) brought suit in Federal District Court.

Issue

Whether the elderly residents of Town Court Nursing Center have a constitutional right to a hearing before a state or federal agency can revoke the home's authority to provide nursing care at government expense.

The question presented is whether approximately 180 elderly residents of a nursing home operated by Town Court Nursing Center, Inc., have a constitutional right to a hearing before a state or federal agency may revoke the home's authority to provide them with nursing care at government expense.

Rule

The court ruled that the patients do not have a constitutional right to continued residence in a nursing home of their choice, and the enforcement of regulations by HEW and DPW does not deprive them of any constitutionally protected interest.

Held: The patients have no interest in receiving benefits for care in a particular facility that entitles them, as a matter of constitutional law, to a hearing before HEW and DPW can decertify that facility.

Analysis

The Supreme Court analyzed the relevant Medicaid provisions and concluded that they do not confer a right to continued residence in a nursing home that has been decertified. The court emphasized that while patients have a right to choose among qualified providers, this does not extend to a right to remain in a decertified facility. The court distinguished between direct benefits and indirect impacts of government action, asserting that the decertification of the nursing home does not constitute a deprivation of life, liberty, or property.

In holding that these provisions create a substantive right to remain in the home of one's choice absent specific cause for transfer, the Court of Appeals failed to give proper weight to the contours of the right conferred by the statutes and regulations.

Conclusion

The Supreme Court reversed the decision of the Court of Appeals, holding that the nursing home residents had no constitutional right to a hearing before the revocation of the home's authority to provide nursing care.

The judgment of the Court of Appeals is reversed, and the case is remanded for further proceedings consistent with this opinion.

Who won?

The prevailing party was the Department of Health, Education, and Welfare and the Pennsylvania Department of Public Welfare, as the Supreme Court ruled in their favor, stating that the patients had no constitutional right to a hearing.

The Secretary of DPW filed a petition for certiorari, which we granted.

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