AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

A minor child, born with cerebral palsy and a seizure disorder, received health care benefits through the New Mexico Human Services Department. Following a medical malpractice settlement, a trust was created to manage the settlement proceeds for the child’s benefit. The Department terminated the child’s Medicaid benefits, asserting that the trust was a "Medicaid qualifying trust" under federal law, making its assets "available" for eligibility purposes (paras 2-7).

Procedural History

• Administrative Appeal from the New Mexico Department of Human Services: The Department determined that the trust was a Medicaid qualifying trust, rendering the child ineligible for benefits.

Parties' Submissions

• Plaintiff-Appellant (Father on behalf of the child): Argued that the Department erred in characterizing the trust as a Medicaid qualifying trust, asserting that the trust was not created by the child and its assets should not be considered "available" for Medicaid eligibility (para 8).
• Defendant-Appellee (New Mexico Human Services Department): Contended that the trust was a Medicaid qualifying trust because it was created by the child’s conservator on his behalf, making the trust assets "available" under federal law (paras 7-8).

Legal Issues

• Was the trust created for the child a "Medicaid qualifying trust" under 42 U.S.C. § 1396a(k)?
• Should the trust assets be considered "available" for determining Medicaid eligibility?

Disposition

• The Court of Appeals reversed the Department’s decision to terminate the child’s Medicaid benefits (para 28).

Reasons

Per Minzner J. (Donnelly and Flores JJ. concurring):

• The court found insufficient evidence to support the Department’s determination that the child was the grantor of the trust. The trust was created through a settlement involving multiple parties, and the child did not have unrestricted legal or equitable title to the funds (paras 19-22).
• The court emphasized that the purpose of 42 U.S.C. § 1396a(k) was to prevent abuse by individuals creating trusts to shield assets while remaining eligible for Medicaid. The trust in this case was created to supplement insufficient public support for the child’s extensive medical needs, not to preserve assets for heirs (paras 15-16, 23-25).
• The court concluded that the trust did not fall within the express or implied intent of Congress in enacting § 1396a(k) and was not a Medicaid qualifying trust. The Department’s exclusion of the child from benefits was therefore contrary to law (paras 26-28).