Blum v. Yaretsky Case Brief

Why is the case important?

The Respondent, Yaretsky (Respondent), is a Medicaid recipient who was transferred from a nursing home to a lower level of care in a health related facility after case review by the nursing home’s utilization review committee. Respondent alleges that this transfer was done in violation of his rights and federal law under the Due Process Clause of the 14th Amendment of the United States Constitution (Constitution).

Facts of the case

Question

Did the decision by a nursing home committee to transfer a Medicaid patient to another facility violate his Due Process rights under the Constitution?

Answer

No. The decision was based on independent medical judgment made by private parties. The fact that the state responded by adjusting the benefits does not make the state responsible for the decision to transfer the patient. There is no indication that these decisions were influenced by the state’s obligations to adjust payment accordingly.

Conclusion

After granting certiorari, the Court concluded that the patients had standing because of the threat of facility-initiated discharges or transfers to lower levels of care was sufficiently substantial. However, the Court held that the district court exceeded its authority in adjudicating the procedures governing transfers to higher levels of care because none of the patients had been threatened with such transfers.  State action was not established in the nursing homes’ decisions to discharge or transfer Medicaid patients to lower levels of care, and therefore, a violation of rights secured by the Fourteenth Amendment was not proven, even though the nursing homes were extensively regulated by the state. Even though the state responded to the discharge or transfer decisions of the nursing homes by adjusting the patients’ Medicaid benefits, the state required the completion of a certain form, the state imposed penalties on nursing homes that failed to discharge or transfer patients whose continued stay was inappropriate, the state subsidized the operating and capital costs of the facilities, the state paid the medical expenses of more than 90 per cent of the patients in the facilities, and the state licensed the facilities, the case involving decisions ultimately turned on medical judgments made by private parties according to professional standards not established by the state, and the nursing homes not performing a function that has traditionally been the exclusive prerogative of the state. The judgment was reversed.

  • Case Brief: 1982
  • Petitioner: Blum
  • Respondent: Yaretsky
  • Decided by: Burger Court

Citation: 457 US 991 (1982)
Argued: Mar 24, 1982
Decided: Jun 25, 1982