Pachas v. N.C. Dep't of Health & Human Servs.

Summary

The Supreme Court of North Carolina held that the superior court had jurisdiction to determine whether the North Carolina Department of Health and Human Services violated its prior Medicaid eligibility order. The court vacated the Court of Appeals decision, which had required exhaustion of administrative remedies, and remanded for consideration of whether the agency’s CAP-DA waiver complied with the prior order and applicable federal law.

Holdings

1. A North Carolina trial court has jurisdiction under Rule 70 to find new facts and determine whether a party disobeyed a prior order directing that party to perform a specific act. The superior court therefore had jurisdiction to determine whether DHHS violated the 17 March 2016 order by terminating Pachas's CAP-DA benefits and requiring a deductible.
2. The Supreme Court did not need to determine whether administrative exhaustion would have been futile or inadequate because the superior court independently had jurisdiction to adjudicate compliance with its own order.
3. Tennessee-Carolina Transportation was inapposite because it concerned the law-of-the-case doctrine, not enforcement of a court order, and did not limit a trial court's Rule 70 jurisdiction to issues involving only the same facts and legal questions decided previously.

Questions Presented

1. Whether the superior court had jurisdiction under Rule 70 of the North Carolina Rules of Civil Procedure to determine whether DHHS violated its prior order by terminating Pachas's Medicaid benefits under the CAP-DA program and requiring a deductible.
2. Whether Pachas was required to exhaust administrative remedies before seeking enforcement of the superior court's prior order.
3. Whether the Court of Appeals improperly relied on law-of-the-case authority to limit the superior court's jurisdiction when new facts and legal issues concerning the CAP-DA waiver arose.

Disposition

vacated