Ramon, by and through next friend, G.C.; Thomas, by and through next friend, C.G.; Cameron, by and through next friend, B.E.; Anthony; and Wendy, on behalf of themselves and those similarly situated v. Juliet Charron, in her official capacity as Director, Idaho Department of Health and Welfare; Sasha O’Connell, in her official capacity as Deputy Director, Idaho Department of Health and Welfare; and Ross Edmunds, in his official capacity as Administrator, Division of Behavioral Health

Summary

The United States District Court for the District of Idaho considers Plaintiffs’ renewed motion for a temporary restraining order and preliminary injunction, as well as a motion for class certification, challenging Idaho’s decision to change Medicaid reimbursement for Assertive Community Treatment services from bundled to unbundled billing. The court analyzes the claims under Title II of the Americans with Disabilities Act and the Rehabilitation Act, including the Olmstead integration mandate and the risk of institutionalization. Based on the record described, the court denies preliminary injunctive relief and denies class certification without prejudice.

Holdings

1. Plaintiffs were not entitled to preliminary injunctive relief because they failed to make a clear showing of likelihood of success on the merits, irreparable harm, and the other required injunction factors.
2. Plaintiffs failed to establish a likelihood of success on the merits because they did not clearly show that unbundling ACT services denied them comparable public benefits or that defendants' action unlawfully discriminated because of disability.
3. Defendants were likely to succeed on their fundamental-alteration defense because restoring bundled ACT services would require Idaho to reduce or eliminate services for other mentally disabled individuals, and plaintiffs did not refute that showing.
4. The motion for class certification was denied without prejudice because the court did not need to decide class-certification issues after denying injunctive relief, and the present record raised substantial concerns about adequacy, individualized inquiries, and regional representation.

Questions Presented

1. Whether plaintiffs made the clear showing required for a preliminary injunction against Idaho officials based on alleged violations of Title II of the ADA and the Rehabilitation Act.
2. Whether plaintiffs demonstrated a likelihood of success on their claim that changing ACT reimbursement from bundled to unbundled billing denied them public benefits or discriminated against them because of disability.
3. Whether plaintiffs demonstrated irreparable harm, favorable equities, and a public interest supporting preliminary injunctive relief.
4. Whether the court should certify plaintiffs' proposed class under Federal Rule of Civil Procedure 23.

Disposition

other