Narrative Opinion Summary
The case involves an appeal by the executrix of an estate challenging a Circuit Court decision that denied her motion to dismiss a claim by the New Hampshire Department of Health and Human Services (DHHS) for Medicaid assistance repayment. The executrix contended that the claim was barred by RSA 556:5, which imposes a one-year statute of limitations for filing suits following the grant of administration. However, DHHS argued that their claim was exempt from this requirement under RSA 167:16, III, which the trial court found to apply broadly to all claims for recovery of assistance, regardless of lien status. The appellant's additional argument that RSA 167:16-a, IV(b)(2) should exempt the estate from recovery was rejected, as the statutory conditions were not met. The court affirmed the trial court's ruling, determining that the exemption was inapplicable due to the absence of a lien and the decedent not being hospitalized. The appellate court upheld the trial court's interpretation of the statutes, allowing DHHS to recover the assistance from the estate.
Legal Issues Addressed
Exemption from Statute of Limitations under RSA 167:16, IIIsubscribe to see similar legal issues
Application: The court interpreted RSA 167:16, III to exempt DHHS's claims from the one-year filing requirement of RSA 556:5, regardless of lien status.
Reasoning: The trial court found ambiguous but interpreted to exempt DHHS from the one-year filing requirement when it has a timely filed claim or a lien on the decedent’s property.
Exemption under RSA 167:16-a, IV(b)(2)subscribe to see similar legal issues
Application: The court found that the exemption under RSA 167:16-a, IV(b)(2) did not apply as there was no lien on the decedent's property due to a medical stay, and the statutory conditions were unmet.
Reasoning: The decedent was not hospitalized, and no lien was placed on their property due to a medical stay, rendering RSA 167:16-a, IV(b)(2) inapplicable.
Statute of Limitations under RSA 556:5subscribe to see similar legal issues
Application: The appellant argued that DHHS's claim was barred by the one-year statute of limitations as DHHS did not file suit within one year of her appointment as executrix.
Reasoning: The appellant argues that DHHS's claim is barred by the statute of limitations under RSA 556:5 because DHHS did not file suit within one year of her appointment as executrix.
Statutory Interpretation under RSA 167:16subscribe to see similar legal issues
Application: The court concluded that RSA 167:16, III applies to all claims for recovery of assistance, rejecting the appellant's interpretation that it applies only to claims secured by liens.
Reasoning: The court concludes that RSA 167:16, III unambiguously applies to all claims for recovery of assistance under the circuit court's jurisdiction, rejecting the appellant's narrower interpretation based on statutory context.