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Leocata ex rel. Gilbride v. Wilson-Coker
United States District Court for the District of Connecticut
343 F. Supp. 2d 144 (2004)
Michela Leocata (plaintiff) was an elderly woman with advanced dementia who resided at Arden Courts, an assisted living facility (ALF) in Connecticut. When Leocata’s assets were nearly depleted and she was unable to pay for continued residence at Arden Courts, she sought Medicaid coverage for her continued care. However, because Medicaid only covered skilled nursing facilities (SNF), not ALFs, Leocata was informed she would need to move into a SNF to obtain Medicaid coverage. Leocata then sued Patricia Wilson-Coker (defendant), the Commissioner of Connecticut’s Department of Social Services, which administered Connecticut’s Medicaid program, arguing that (1) under the Equal Protection Clause, Connecticut’s Medicaid program violated Leocata’s rights as an elderly disabled person because it provided coverage to elderly disabled SNF residents but not to elderly disabled ALF residents; and (2) under the Due Process Clause, Connecticut’s failure to cover ALF care restricted Leocata’s property interest in receiving Medicaid coverage and her liberty interest in being able to choose her own place of residence. Leocata alleged that a SNF would not meet her special needs and that the higher level of care at an SNF would be unduly restrictive. Wilson-Coker moved to dismiss for failure to state a claim.
Rule of Law
Holding and Reasoning (Droney, J.)
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