John B. v. Goetz

Summary

The Sixth Circuit reviewed the denial of Tennessee officials’ motion to vacate a consent decree governing the state’s TennCare Medicaid program. The court declined to vacate the decree in its entirety but vacated provisions based on the Medicaid statute’s geographically comparable-services requirement, remanded for consideration of other provisions, and ordered reassignment of the case to a different district judge.

Holdings

1. The consent decree should not be vacated in its entirety because the record did not show that the decree as a whole was undermined by intervening precedent, and Sixth Circuit precedent recognized that at least the Medicaid outreach requirement in 42 U.S.C. § 1396a(a)(43)(A) could be enforced through § 1983.
2. The consent decree's requirement that defendants ensure geographically comparable availability of services, and any other decree provisions based on 42 U.S.C. § 1396a(a)(30), must be vacated because that provision is not privately enforceable under § 1983.
3. The enforceability of decree provisions concerning actual service provision, waiting lists under § 1396a(a)(43)(C), the remaining portions of § 1396a(a)(43), and the Adoption Assistance Act should be determined by the district court in the first instance after supplemental briefing.
4. Reassignment to a different judicial officer was warranted because the district court's treatment of the record, prolonged lack of progress, and increasingly adversarial management created an appearance that defendants might not receive fair consideration.

Questions Presented

1. Whether intervening Sixth Circuit precedent required vacatur of the consent decree in its entirety under Federal Rule of Civil Procedure 60(b).
2. Whether the consent decree's requirement that defendants ensure geographically comparable availability of services was enforceable under 42 U.S.C. § 1983.
3. Whether the enforceability of other decree provisions, including provisions concerning actual service provision, waiting lists, and adoption assistance, should be determined by the district court on remand.
4. Whether the case should be reassigned to a different district judge.

Disposition

vacated