Supreme Court of the United States

Gallardo v. Marstiller

June 17, 2022

Summary

Justice Thomas, writing for seven Justices, held that the Medicaid Act permits a State to reimburse itself for medical expenses already paid from settlement funds allocated to future medical care. Section 1396k(a)(1)(A) assigns rights to payment for medical care without distinguishing past from future expenses, bringing Florida’s assignment statute within an exception to the Act’s anti-lien provision. The Court also rejected the suggestion that its interpretation permits lifetime assignments of rights acquired after Medicaid eligibility ends, and affirmed the Eleventh Circuit. Justice Sotomayor, joined by Justice Breyer, dissented, arguing that the reimbursement provisions, read together with the Act’s protections for beneficiaries’ property, permit recovery only from settlement payments compensating for care Medicaid actually furnished.

Holding

  • Recovery from settlement payments allocated to future medical care.. The Medicaid Act permits a State to seek reimbursement for medical expenses already paid from settlement amounts representing payment for either past or future medical care.
  • Whether §1396k(a)(1)(A) authorizes a lifetime assignment.. Section 1396k(a)(1)(A) does not authorize a lifetime assignment encompassing rights acquired after an individual is no longer a Medicaid beneficiary.

Docket 20-1263

Cited authorities

  • Fla. Stat. §409.910
  • Fla. Stat. §409.910