Case: Long v. Benson

4:08-cv-00026 | U.S. District Court for the Northern District of Florida

Filed Date: Jan. 15, 2008

Closed Date: 2012

Clearinghouse coding complete

Case Summary

On January 15, 2008, a group of Medicaid-eligible adults with disabilities that were confined to a nursing-home facility filed a class action in the U.S. District Court for the Northern District of Florida under the ADA and the Rehabilitation Act against the state's Health Care Administration and Department of Elder Affairs. The plaintiffs, represented by public interest attorneys, asked the Court for declaratory and injunctive relief, alleging that the state discriminated against them by faili…

On January 15, 2008, a group of Medicaid-eligible adults with disabilities that were confined to a nursing-home facility filed a class action in the U.S. District Court for the Northern District of Florida under the ADA and the Rehabilitation Act against the state's Health Care Administration and Department of Elder Affairs. The plaintiffs, represented by public interest attorneys, asked the Court for declaratory and injunctive relief, alleging that the state discriminated against them by failing to offer services that would enable them to live in a community setting.

On June 7, 2008, the Court (Judge Robert L. Hinkle) denied defendants' motion to dismiss. On October 14, 2008, Judge Hinkle certified the class consisting of any Florida Medicaid-eligible adult who, at any time during the litigation, resided in a nursing home that received Medicaid funding, and who could and would have resided in the community with appropriate community-based services.

At the same time, the judge granted a preliminary injunction with regard to one of the named plaintiffs, Clayton Griffith. Griffith lived in a nursing home, the cost of which was covered by the state's Medicaid program. He had applied for and been determined eligible for a waiver that should have allowed him to live in the community rather than an institution. But the state's long waiting list precluded him from accessing the program. Nevertheless, he moved out of the home and into an apartment. Judge Hinkle entered an injunction ordering the state to provide Griffith Medicaid coverage for a certified nursing assistant. The state appealed the preliminary injunction, which the 11th Circuit affirmed on June 22, 2010.

The parties cross-moved for summary judgment; the judge denied both motions on January 19, 2011.

After a February 2011 bench trial, Judge Hinkle issued an order and opinion on January 3, 2012 that made permanent the injunction regarding Griffith, dismissed the other named plaintiffs' claims as moot, and decertified the class. To start, all but one of the other named plaintiffs had died during the course of litigation; the remaining one had decided to stay in the nursing home. The judge decertified the class in part because the state legislature had passed a new law which greatly improved the rate at which Medicaid-eligible adults were transitioned from nursing homes to community living. Post-legislation, Judge Hinkle reasoned, it was no longer true that the state had refused to act on grounds that applied generally to the class. He concluded that where the conditions that made class-certification appropriate are no longer present, the court has discretion to decertify, which he chose to do.

Summary Authors

Kunyi Zhang (2/5/2011)

Andrew Junker (10/22/2014)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/4816258/parties/lee-v-benson/


Judge(s)

Birch, Stanley F. Jr. (Georgia)

Attorney for Plaintiff

Canan, Stacy (District of Columbia)

Chonin, Neil (Florida)

Attorney for Defendant

Bennett, Kelly Ann (Florida)

Blocker, William Michael II (Florida)

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Documents in the Clearinghouse

Document

4:08-cv-00026

Docket

May 10, 2012

May 10, 2012

Docket
1

4:08-cv-00026

Complaint

Jan. 15, 2008

Jan. 15, 2008

Complaint
13

4:08-cv-00026

Amended Class Action Complaint for Declaratory and Injunctive Relief

Feb. 19, 2008

Feb. 19, 2008

Complaint
68

4:08-cv-00026

Order Denying Motion to Dismiss and Deferring Ruling on Class Certification

June 7, 2008

June 7, 2008

Order/Opinion
135

4:08-cv-00026

Order Granting Preliminary Injunction

Oct. 14, 2008

Oct. 14, 2008

Order/Opinion

2008 WL 2008

136

4:08-cv-00026

Order Certifying Class

Oct. 14, 2008

Oct. 14, 2008

Order/Opinion

2008 WL 2008

08-16261

11th Circuit Opinion (Affirming District Court's grant of a Preliminary Injunction)

U.S. Court of Appeals for the Eleventh Circuit

June 22, 2010

June 22, 2010

Order/Opinion

383 Fed.Appx. 383

336

4:08-cv-00026

Order Denying Summary Judgment

Jan. 19, 2011

Jan. 19, 2011

Order/Opinion
372

4:08-cv-00026

Order and Opinion [directing the entry of judgment from the plaintiff Griffith, dismissing the other named plaintiffs as moot, and decertifying the class]

Lee v. Dudek

Jan. 3, 2012

Jan. 3, 2012

Order/Opinion

Docket

See docket on RECAP: https://www.courtlistener.com/docket/4816258/lee-v-benson/

Last updated March 21, 2024, 3:04 a.m.

ECF Number Description Date Link Date / Link
135

PRELIMINARY INJUNCTION. Granting 123 Motion for Preliminary Injunction as to Plaintiff Clayton Griffin. Signed by CHIEF JUDGE ROBERT L HINKLE on 10/14/08. (pll)

Oct. 14, 2008

Oct. 14, 2008

RECAP
136

ORDER CERTIFYING CLASS. Granting 22 Motion to Certify Class. Signed by CHIEF JUDGE ROBERT L HINKLE on 10/14/08. (pll)

Oct. 14, 2008

Oct. 14, 2008

RECAP

Case Details

State / Territory: Florida

Case Type(s):

Public Benefits/Government Services

Special Collection(s):

Olmstead Cases

Multi-LexSum (in sample)

Key Dates

Filing Date: Jan. 15, 2008

Closing Date: 2012

Case Ongoing: No

Plaintiffs

Plaintiff Description:

A group of Florida residents who were Medicaid eligible adults with disabilities but were currently confined to a nursing facility.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

Steve Gold

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

State of Florida, State

Case Details

Causes of Action:

Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.

Section 504 (Rehabilitation Act), 29 U.S.C. § 701

Available Documents:

Trial Court Docket

Complaint (any)

Injunctive (or Injunctive-like) Relief

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Attorneys fees

Preliminary injunction / Temp. restraining order

Source of Relief:

Litigation

Order Duration: 2012 - 0

Content of Injunction:

Preliminary relief granted

Implement complaint/dispute resolution process

Issues

General:

Access to public accommodations - governmental

Classification / placement

Housing

Public benefits (includes, e.g., in-state tuition, govt. jobs)

Jails, Prisons, Detention Centers, and Other Institutions:

Confinement/isolation

Habilitation (training/treatment)

Disability and Disability Rights:

disability, unspecified

Mental impairment

Intellectual/developmental disability, unspecified

Discrimination-basis:

Disability (inc. reasonable accommodations)

Medical/Mental Health:

Medical care, general

Type of Facility:

Non-government non-profit

Benefit Source:

Medicaid