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A federal program established under the Social Security Act that provides health insurance for the elderly and the disabled.
Maurice Marshall, a lawful permanent resident who arrived in the United States four years ago, applies for Medicare hospital coverage after turning sixty-five. Federal regulations require five years of residency before eligibility attaches. The agency denies his application. The denial stands because Congress holds plenary power over immigration and may draw alienage lines in federal benefit programs without strict scrutiny.
Monica Morgan lies in a persistent vegetative state after an automobile accident. Her physicians order artificial nutrition and hydration through a feeding tube. Medicare covers the cost of the device and formula because the federal program treats enteral feeding as a reimbursable medical service analogous to other life-sustaining equipment.
On the night of January 11, 1983, Nancy Beth Cruzan lost control of her car as she traveled down Elm Road in Jasper County, Missouri. The vehicle overturned, and Cruzan was discovered lying face down in a ditch without detectable respiratory or cardiac function. Paramedics were able to restore her breathing and heartbeat at the accident site, and she was transported to a hospital in an unconscious state. An attending neurosurgeon diagnosed her as having sustained probable cerebral contusions compounded by significant anoxia. The Missouri trial court found that permanent brain damage generally results after six minutes in an anoxic state, and it was estimated that Cruzan was deprived of oxygen from twelve to fourteen minutes. She remained in a coma for approximately three weeks and then progressed to an unconscious state in which she was able to orally ingest some nutrition. Surgeons implanted a gastrostomy feeding and hydration tube in Cruzan with the consent of her then husband. Subsequent rehabilitative efforts proved unavailing. She now lies in a Missouri state hospital in what is commonly referred to as a persistent vegetative state in which a person exhibits motor reflexes but evinces no indications of significant cognitive function. The State of Missouri is bearing the cost of her care. After it had become apparent that Nancy Cruzan had virtually no chance of regaining her mental faculties, her parents Lester and Joyce Cruzan, who serve as coguardians, asked hospital employees to terminate the artificial nutrition and hydration procedures. All agree that such a removal would cause her death. The employees refused to honor the request without court approval. The parents then sought and received authorization from the state trial court for termination. The trial court found that a person in Nancy's condition had a fundamental right under the State and Federal Constitutions to refuse or direct the withdrawal of death prolonging procedures. The court also found that Nancy's expressed thoughts at age twenty-five in conversation with a housemate friend suggested that given her present condition she would not wish to continue on with her nutrition and hydration. The Supreme Court of Missouri reversed by a divided vote. The court recognized a right to refuse treatment embodied in the common-law doctrine of informed consent but expressed skepticism about the application of that doctrine in the circumstances of this case. The court found that Cruzan's statements to her roommate regarding her desire to live or die under those conditions were unreliable for determining her intent and thus insufficient to support the coguardians' claim to exercise substituted judgment on Nancy's behalf. It rejected the argument that Cruzan's parents were entitled to order the termination of her medical treatment, concluding that no person can assume that choice for an incompetent in the absence of the formalities required under Missouri's Living Will statutes or the clear and convincing inherently reliable evidence absent here. The Supreme Court granted certiorari to consider the question whether Cruzan has a right under the United States Constitution which would require the hospital to withdraw life-sustaining treatment from her under these circumstances.
View caseMidwest Airlines offers its employees minimum essential health coverage through a group plan rather than requiring them to purchase individual policies. The plan satisfies the federal individual mandate because employees receive coverage through a government-recognized program such as Medicare when they later qualify by age or disability.
In 2010 Congress enacted the Patient Protection and Affordable Care Act containing hundreds of provisions across ten titles. The Act requires most Americans to maintain minimum essential health insurance coverage beginning in 2014 or else make a shared responsibility payment calculated as a percentage of household income subject to a floor and ceiling. The Act also expands Medicaid by requiring participating states to cover adults with incomes up to 133 percent of the federal poverty level while increasing federal funding but threatening loss of all Medicaid funds for noncompliance. On the day the President signed the Act Florida and twelve other states filed suit in the United States District Court for the Northern District of Florida challenging the individual mandate provisions under Article I. The original plaintiffs were later joined by eighteen additional states several individuals and the National Federation of Independent Business. The District Court held that the individual mandate exceeded congressional power and could not be severed from the remainder of the Act so it struck down the entire statute. The Court of Appeals for the Eleventh Circuit affirmed that the individual mandate exceeded congressional power but held the provision severable from the rest of the Act while unanimously upholding the Medicaid expansion. Other courts of appeals reached conflicting results on the mandate with the Sixth Circuit and the D.C. Circuit upholding it under the commerce power and the Fourth Circuit applying the Anti-Injunction Act to bar review. The Supreme Court granted certiorari to review the Eleventh Circuit judgment on both the individual mandate and the Medicaid expansion and appointed amici curiae to address severability and the Anti-Injunction Act. The penalty for noncompliance with the individual mandate first becomes enforceable in 2014. The present suit seeks to restrain its future collection. The Act describes the payment as a penalty rather than a tax. It directs that the payment be assessed and collected in the same manner as taxes but bars the IRS from using criminal prosecutions or levies to enforce it.
View caseMelanie Morris purchases a health plan through the federal exchange and receives premium tax credits. When she turns sixty-five she becomes eligible for Medicare. The exchange terminates her subsidy because Medicare constitutes minimum essential coverage that displaces exchange assistance under the statute.
The Patient Protection and Affordable Care Act was enacted in 2010 after earlier state-level attempts at insurance market reforms in the 1990s produced adverse selection and rising premiums. The Act combined guaranteed-issue and community-rating requirements with an individual coverage mandate and refundable tax credits for households earning between 100 and 400 percent of the federal poverty line. It directed each State to establish an American Health Benefit Exchange but provided that the Secretary of Health and Human Services would establish and operate such an Exchange if a State did not. Sixteen States and the District of Columbia created their own Exchanges; the remaining thirty-four States, including Virginia, have Federal Exchanges operated by HHS. The IRS promulgated a regulation in 2012 interpreting the tax-credit provisions to apply to insurance purchased on any Exchange, whether established by a State or by the Federal Government. Petitioners, four Virginia residents who did not wish to purchase health insurance, filed suit in the Eastern District of Virginia challenging that regulation. The district court dismissed the complaint, concluding that the statute unambiguously made credits available on Federal Exchanges. The Fourth Circuit affirmed, treating the statute as ambiguous and deferring to the IRS interpretation under Chevron. On the same day the Fourth Circuit ruled, the D.C. Circuit reached the opposite conclusion in a separate case and vacated the IRS rule. The Supreme Court granted certiorari to resolve the conflict.
View caseMegan Moore, a widower, seeks Social Security survivor benefits after his spouse's death. The wage earner's Medicare taxes paid during employment help fund the benefit stream. The agency awards benefits because the deceased spouse's contributions satisfied the eligibility requirements under the linked federal insurance programs.
Stephen C. Wiesenfeld and Paula Polatschek married on November 15, 1970. Paula worked as a teacher both before and after the marriage, with maximum social security contributions deducted from her salary each year. Her earnings substantially exceeded Stephen's and constituted the couple's principal source of support, as shown by her 1970 earnings of $9,808 against his $3,100, her 1971 earnings of $10,686 against his $2,188, and her 1972 earnings of $6,836.35 before her death. On June 5, 1972, Paula died in childbirth, leaving Stephen with sole responsibility for their infant son, Jason Paul. Stephen applied at the Social Security office in New Brunswick, New Jersey, for survivors' benefits for himself and his son. His son received benefits under 42 U.S.C. § 402(d) (1970 ed. and Supp. III), initially at $206.90 per month until September 1972 and then at $248.30 per month. Stephen was told he was ineligible for benefits on his own behalf because such benefits were available only to women. Stephen filed suit in February 1973 in the District of New Jersey on behalf of himself and all similarly situated widowers, seeking a declaration that the statute was unconstitutional to the extent it treated men and women differently, an injunction against denial of benefits on the basis of sex, and payment of past benefits from June 1972. Cross-motions for summary judgment were filed. A three-judge court determined it had jurisdiction and granted summary judgment in Stephen's favor, issuing an order providing the requested relief. The Supreme Court noted probable jurisdiction.
View caseMedicare covers individuals over age sixty-five and certain disabled persons. It operates as a federal health insurance program distinct from Medicaid, which serves the poor.
Federal Medicare rules may impose a five-year residency requirement on aliens. Such classifications receive rational-basis review and are upheld when not arbitrary.
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Medicare treats enteral feeding devices and formulas as covered medical foods and devices when they support bodily functions compromised by illness.
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