Christopher W. G., by and through his Conservators Gary G. and Kathleen G. v. Frank Bisignano

Summary

The United States District Court for the Central District of California affirmed the Commissioner of Social Security’s denial of Supplemental Security Income benefits to Christopher W. G. The court held that the plaintiff’s special needs trust did not qualify for exclusion from countable resources under 42 U.S.C. § 1396p(d)(4)(A) because its language potentially permitted payment of third-party debts and other obligations before Medicaid reimbursement. The action was dismissed with prejudice.

Holdings

1. The special needs trust did not satisfy 42 U.S.C. § 1396p(d)(4)(A) because its language permitted payment of third-party debts and other obligations before reimbursement to the state for Medicaid assistance.

Questions Presented

1. Whether the special needs trust satisfied the exception to resource counting under 42 U.S.C. § 1396p(d)(4)(A).
2. Whether substantial evidence supported the ALJ's determination that the trust permitted payment of third-party debts or other obligations before reimbursement to the state.

Disposition

dismissed