Justia U.S. 4th Circuit Court of Appeals Opinion Summaries

Plaintiff sued defendant seeking a declaratory judgment that defendant was required to comply with the rules laid out in Title XIX of the Social Security Act, section 1396-1396v, where there was a dispute as to what rate plaintiff must pay defendant when defendant provided emergency transportation services to plaintiff's Medicaid enrollees. At issue was whether the definition of emergency services in section 1396(u)-2(b)(2)(B) applied to section 1396(u)-2(b)(2)(D) and whether section 1396(u)-2(b)(2)(D) covered the services provided by defendants to members of plaintiff's Medicaid program. The court held that the definition of emergency services found in 1396(u)-2(b)(2)(B) applied to section 1396(u)-2(b)(2)(D) where applying different definitions to a single term of art within this one statute would be both cumbersome and illogical. The court also held that the district court erred in granting summary judgment to defendant where the plain meaning of the word outpatient and the structure of the statute supported a finding in favor of plaintiff.

Plaintiff, on her child's behalf, applied for survivorship benefits under the Social Security Act where the child was conceived by in vitro fertilization after the child's biological father, plaintiff's husband, passed away a number of years before the child was conceived. At issue was whether natural children, such as plaintiff's child, plainly fell within 42 U.S.C. 416(e)(1)'s basic definition of "child," and therefore making their intestacy rights irrelevant. The court held that the Social Security Administration's denial of survivorship benefits best reflected the statute's text, structure, and aim of providing primarily to those who unexpectedly lose a wage earner's support and that this view fell well within the range of permissible readings entitled to deference under Chevron U.S.A. Inc. v. Natural Resources Defense Council.