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Alexander v. Choate

469 U.S. 287 (1985)

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Alexander v. Choate

United States Supreme Court

469 U.S. 287 (1985)

Facts

To save money, the Tennessee Medicaid program reduced the number of inpatient hospital days covered under the program from 21 to 14 days per year. Although there was no indication that the reduction was meant to harm disabled people, it disproportionately impacted disabled Medicaid recipients. Specifically, 27.4 percent of disabled Medicaid recipients needed more than 14 days of hospital care each year as compared with only 7.8 percent of Medicaid recipients without disabilities. A group of disabled Tennessee Medicaid recipients (plaintiffs) filed a class action against the governor of Tennessee (defendant), arguing that the reduction discriminated against disabled people in violation of § 504 of the Rehabilitation Act. In the alternative, the class claimed that any general limit on the number of inpatient hospital days per year discriminated against disabled people. The class argued that Tennessee could use a less discriminatory system to control overnight costs by tailoring any hospital-stay limits to the treatment being received. The Sixth Circuit held that a prima facie cause of a § 504 violation had been established and remanded the case to the state for rebuttal. Certiorari was granted.

Rule of Law

Issue

Holding and Reasoning (Marshall, J.)

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