Christensen v. North Dakota Department of Human Services

Summary

The North Dakota Supreme Court affirmed a district court judgment upholding the Department of Human Services’ determination that Edward Christensen was ineligible for Medicaid benefits from April through August 2008. The court held that Christensen’s interests in California real estate and the proceeds from its sale were actually available assets until the proceeds were transferred to the nursing home, exceeding the applicable Medicaid asset limit.

Holdings

1. Christensen failed to prove that his interests in the California properties or the proceeds from their sale were unavailable. The properties remained at his disposal until the sales closed, and the proceeds remained legally and practically available while held unrestricted in his personal checking account until transferred to the nursing home.
2. The Department of Human Services did not err in determining that Christensen's real estate interests and sale proceeds were actually available assets and that he was ineligible for Medicaid benefits from April through August 2008.

Questions Presented

1. Whether the Department of Human Services properly determined that Christensen's interests in the California real estate were actually available assets before the sales closed.
2. Whether the proceeds from the California real estate sales remained actually available assets while held unrestricted in Christensen's personal checking account, despite an alleged agreement to pay the proceeds to the nursing home.
3. Whether the Department's factual findings and eligibility determination were supported under the Administrative Agencies Practice Act.

Disposition

affirmed