Mitchell v. Johnston
United States Court of Appeals for the Fifth Circuit
701 F.2d 337 (1983)
- Written by Samantha Arena, JD
Facts
In exchange for federal funds under the Social Security Act, states participating in the Medicaid program must provide minimum mandatory services, including Early and Periodic Screening, Diagnosis, and Treatment (EPSDT) covering dental care for children of eligible Medicaid recipients. Texas implemented an EPSDT program under which children could obtain annual dental checkups and related services. After state budget cuts affected funding to the program, the Texas Department of Human Resources (TDHR) (defendant) reduced EPSDT services by changing the frequency of covered dental checkups from once a year to once every three years. Exceptions to the three-year period were only permitted in circumstances of emergency, obvious need, or medical necessity. TDHR also removed eight previously available services from the program, including topical fluoride and root canals. Medicaid recipients affected by the cuts, including Stephanie and Stephen Mitchell (the recipients) (plaintiffs), sued Acting Commissioner of TDHR Marlin Johnston (defendant), contending that the cuts violated federal law. The district court found in the recipients’ favor. TDHR appealed.
Rule of Law
Issue
Holding and Reasoning (Johnson, J.)
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