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appealhearingtrialtrustwill
plaintiffdefendantappealhearingtrialtrustregulationvisa

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Pikula v. Department of Social Services, 321 Conn. 259, 138 A.3d 212

Facts

In 1989, John Pikula executed a will establishing a testamentary trust for his daughters, including Marian Pikula. After his death in 1991, the trust became effective, with a trustee appointed to manage it. In March 2012, Marian applied for Medicaid benefits while residing in a long-term care facility, but her application was denied in May 2013 because the trust's value exceeded Medicaid asset limits. Following a hearing, the denial was upheld, leading to Marian's appeal.

The plaintiff, Marian Pikula, appeals from the judgment of the trial court dismissing her appeal from the decision of an administrative hearing officer for the defendant, the Department of Social Services (department), denying her application for benefits under the state administered Medicaid program because her assets, in the form of a testamentary trust, exceeded prescribed Medicaid limits.

Issue

Did the trial court err in upholding the hearing officer's determination that the assets of Marian Pikula's testamentary trust were available for Medicaid eligibility purposes?

The plaintiff claims that the trial court improperly upheld the hearing officer's conclusion that the trust was an asset available to the plaintiff as defined by relevant Medicaid regulations.

Rule

For Medicaid eligibility, only assets that are actually available to the applicant can be considered. A supplemental needs trust, where the trustee has discretion to withhold distributions, is not deemed an available asset.

For the purposes of determining eligibility for the Medicaid program, an available asset is one that is actually available to the applicant or one that the applicant has the legal right, authority or power to obtain or to have applied for the applicant's general or medical support.

Analysis

The court analyzed the language of the testamentary trust, noting that the trustee had sole and absolute discretion to determine distributions for Marian's support. This discretion indicated that the trust was intended to be a supplemental needs trust, as the testator did not intend for the trust assets to be available for general support. The court compared this case to previous rulings, emphasizing the importance of the testator's intent and the discretion granted to the trustee.

The language set forth previously in this opinion indicates that the trustee in the present case need only use as much income from the trust 'as the [t]rustee may deem advisable' to the plaintiff.

Conclusion

The Supreme Court concluded that the trial court improperly dismissed Marian's appeal and that the assets of the trust should not be considered available for Medicaid eligibility. The court reversed the trial court's judgment and remanded the case.

Accordingly, we conclude that the trial court improperly dismissed the plaintiff's appeal from the decision of the hearing officer determining that the trust in the present case was a general needs trust for the purpose of eligibility for Medicaid benefits.

Who won?

Marian Pikula prevailed in the case because the Supreme Court found that the trust was a supplemental needs trust, thus its assets were not available for Medicaid eligibility.

The Supreme Court held that the trial court should not have dismissed the appeal on the ground that the hearing officer correctly determined that the trust was an asset available to the plaintiff.

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