Blum v. Yaretsky

Yaretsky and Cuevas (plaintiffs) were patients in the American Nursing Home, a high-level care facility located in New York City. Both men received Medicaid benefits from the State of New York to pay for their care. As part of the conditions for their receipt of Medicaid benefits, the State of New York established a “utilization review committee” (URC) to determine whether nursing home patients met the income requirements for Medicaid and whether they sought necessary medical treatment. Based on standard procedure, if the URC determined that patients required less or more care, it recommended to state Medicaid officials that patients be discharged or transferred to facilities offering different levels of care and Medicaid benefits adjusted accordingly. In Yaretsky and Cuevas’ case, the URC determined that they needed less care and recommended that they be transferred to a lower-level facility. After administrative hearings, New York City officials determined that their Medicaid benefits would cease if they did not accept the recommended transfer. Yaretsky and Cuevas then commenced this suit on behalf of themselves and a class of Medicaid recipients in New York City nursing homes. They named Blum, Commissioner of the New York Department of Social Services, and Commissioners of the Department of Health as defendants. Yaretsky and Cuevas alleged that Blum and Commissioners had not afforded them adequate notice of the URC decisions or their right to an administrative hearing to challenge those decisions. The district court granted Yaretsky and Cuevas injunctive relief, and the court of appeals, finding that state action occurred, affirmed. The United States Supreme Court granted certiorari.