Curtis v. Taylor

In 1977 Florida amended its Medicaid plan to cover only three nonemergency physician visits per month. Florida’s amendment to its plan was similar to amendments that other states had enacted, which the Department of Health, Education, and Welfare (the department) had approved. Margarette Curtis and others requiring more than three nonemergency physician visits per month (collectively, the Medicaid enrollees) (plaintiffs) sued Florida Secretary of State Alvin J. Taylor (the state) (defendant). The Medicaid enrollees argued that the amendment violated a federal regulation that prohibited discriminating against a particular diagnosis, illness, or condition. The state provided data indicating that most individuals on Medicaid did not require more than three nonemergency physician visits per month. In response, the Medicaid enrollees argued that, because some individuals required more than three nonemergency physician visits per month, the state was prohibited from imposing a three-visit restriction because doing so resulted in the denial of medically necessary treatment for those individuals. The district court returned a verdict in the Medicaid enrollees’ favor on the ground that the limitation violated the federal regulation because the emergency-coverage exception discriminated between less severe conditions requiring nonemergency physician visits and more severe conditions requiring emergency physician visits. The matter was appealed.