In 1972, a permanent resident alien of the United States brought a 42 U.S.C. § 1983 class action in the U.S. District Court for the Northern District of California, seeking an injunction against the enforcement of California's Medically Indigent Law, Calif.Wel. & Inst.Code § 14005.6(a)(3). Plaintiff alleged that the Law violated the Equal Protection Clause in that it conditioned eligibility for state indigent health care services on either being a U.S. citizen or having been in the U.S. for five years. Plaintiff sought declaratory and injunctive relief, as well as class certification.

A three-judge panel (consisting of Judges William G. East, Montgomery O. Koelsch, and William T. Sweigert) was convened in the District Court to determine the constitutionality of the Law. On June 29, 1972, the District Court (Judge Sweigert) certified a plaintiff class consisting of "all resident aliens of California whose applications for Medi-Cal aid have been denied since October 1, 1971 solely on the ground of non-compliance with the requirements of Section 14005.6(a)(3)." The Court found that that statute denied Plaintiffs equal protection and enjoined its enforcement. Yuan Jen Cuk v. Brian, 355 F.Supp. 133 (N.D. Cal. 1972). Defendant appealed. The Ninth Circuit reversed and remanded the case for decision by the three-judge panel. Yuan Jen Cuk v. Lackner, 537 F.2d 1064 (9th Cir. 1976).

The three-judge panel heard the case on remand. On July 25, 1977, the panel issued its opinion and concluded that Plaintiffs were not entitled to retroactive monetary relief for wrongfully denied benefits because the state enjoyed 11th Amendment immunity. As such, Plaintiffs were entitled only to prospective injunctive relief. The challenged section of the Medically Indigent Law, § 14005.6, however, had been repealed in its entirety while the case was on appeal. As such, the panel determined that the remaining case issues were moot and that the case should be dismissed. Yuan Jen Cuk v. Lackner, 448 F.Supp. 4 (N.D. Cal. 1977).

Stephen Imm - 08/23/2007


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