Waskul v. Washtenaw County Community Mental Health
Not reported in official reporter (2021)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A federal court will not abstain from exercising its jurisdiction under Burford, Rooker-Feldman, or Colorado River doctrines where state court proceedings do not involve complex state regulatory schemes requiring federal deference, do not review federal court judgments, and are not substantially parallel to the federal action.
Facts:
- Derek Waskul, Cory Schneider, Kevin Weisner, and Hannah Ernst are individuals with severe developmental disabilities residing in Washtenaw County, Michigan.
- These individuals receive Community Living Supports (CLS) services through Medicaid's Habilitation Supports Waiver (HSW) program, which enables them to live independently in the community as an alternative to institutionalization.
- The CLS program utilizes a Person-Centered Planning Process (PCP) to develop an Individual Plan of Service (IPOS) based on each participant's medical needs, and a budget is then calculated to cover these identified services.
- In May 2015, a reduction in the CLS rate calculation took effect, leading to a decrease in the total budget amount for recipients, which served as the original impetus for this litigation.
- Despite subsequent increases that raised CLS rates above pre-May 2015 levels, Plaintiffs continued to challenge the existing budget calculation method as fundamentally inadequate to account for all of their medically necessary services.
- In 2019, Plaintiff Kevin Weisner filed an internal appeal with Washtenaw County Community Mental Health (CMH) seeking an increase in his individual CLS rate to $18/hour, which was subsequently denied.
Procedural Posture:
- March 15, 2016: Plaintiffs Derek Waskul, Cory Schneider, Kevin Wiesner, and WACA commenced this action in the U.S. District Court for the Eastern District of Michigan.
- November 22, 2016: The U.S. District Court denied Plaintiffs’ Motion for Preliminary Injunction.
- December 15, 2016: Plaintiffs appealed the denial of preliminary injunction to the Sixth Circuit Court of Appeals, challenging the ruling on WACA's associational standing.
- August 14, 2018: The Sixth Circuit Court of Appeals affirmed the District Court's denial of injunctive relief on narrow grounds, finding the named Plaintiffs' due process claims were moot, thus WACA lacked associational standing for injunctive relief.
- February 11, 2019: Plaintiffs filed an Amended Complaint in the U.S. District Court, alleging various federal and state law violations related to the CLS budgeting methodology.
- March 20, 2019: The U.S. District Court granted Defendants' motions to dismiss the Amended Complaint, closing the case.
- Upon Plaintiffs' appeal, the Sixth Circuit Court of Appeals reversed the District Court's dismissal and remanded the case for further proceedings.
- November 5, 2019: Separately, Plaintiff Kevin Weisner requested a state fair hearing to appeal CMH’s denial of his individual CLS budget increase.
- January 6, 2020: A state Administrative Law Judge (ALJ) reversed CMH’s denial and ordered CMH to reassess Weisner's budget.
- CMH appealed the ALJ decision to the Washtenaw County Circuit Court (a state trial court), which subsequently vacated the ALJ's decision, ruling the ALJ had acted 'beyond the scope of authority.'
- Weisner sought leave to appeal the Washtenaw County Circuit Court's decision to the Michigan Court of Appeals (a state intermediate appellate court).
- February 8, 2021: Defendants filed a Joint Motion for Abstention with the U.S. District Court for the Eastern District of Michigan.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a federal district court have grounds to abstain from hearing a case challenging a state's Medicaid budgeting methodology when a related individual state court proceeding does not address the overall methodology, the federal case was filed prior to the state case, and no complex state regulatory scheme requires federal deference?
Opinions:
Majority - Arthur J. Tarnow, Senior United States District Judge
No, a federal district court does not have grounds to abstain from hearing this case. The court first addressed Burford abstention, which applies when a state has an overriding interest and superior competence in a complex state regulatory scheme. The court found no timely and adequate state review of the overall CLS budget methodology, noting that while the federal case touches on state policy, it merely questions whether the budget system violates federal and state law, not attempting to shape its inner workings. The court also observed that Weisner's state case primarily concerned state courts' jurisdiction over administrative decisions, not the methodology itself, thus failing the 'adequate state review' prong of Burford. Next, the court considered the Rooker-Feldman doctrine, which bars federal district courts from reviewing state-court judgments. This doctrine was deemed inapplicable because Plaintiffs' federal case was filed years before Weisner's state court proceedings began, and it seeks systemic relief (a finding that the budget calculation method is unlawful for all plaintiffs) that no state court has previously denied. The court emphasized that an increase in Weisner's individual rate does not change the broader budget methodology, therefore the claims are not 'inextricably intertwined.' Finally, the court analyzed Colorado River abstention, which permits abstention in 'exceptional circumstances' involving contemporaneous federal and state jurisdiction based on judicial economy and federal-state comity. The court reiterated that abstention is the exception, not the rule, and found no exceptional circumstances, complex issues, or evidence of greater expertise in the Michigan courts to warrant it. Crucially, Weisner's state court proceedings were not 'substantially similar' or 'parallel' to the federal case because the state court focused on individual budget increases and jurisdictional questions, while the federal court addresses the systemic budget methodology for all plaintiffs. Given these distinctions, the court declined to abstain.
Analysis:
This ruling highlights the stringent requirements for federal courts to invoke abstention doctrines, particularly when federal rights are at stake in state-administered programs. It clarifies that individual state-level administrative or judicial actions concerning specific benefits do not render broader federal challenges to systemic methodologies 'parallel' or 'inextricably intertwined' for abstention purposes. The decision reinforces the principle that federal courts have a strong obligation to exercise their jurisdiction unless state proceedings offer a truly adequate and comprehensive review of the specific federal questions presented. This limits states' ability to force federal litigation into state forums and preserves federal court access for individuals challenging widespread program deficiencies.
