Thanks for visiting! Welcome to a new way to research case law. You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.
J.C.M. v. Agency (In re Ala. Medicaid Agency)
Citation: 267 So. 3d 326Docket: 2170748
Court: Court of Civil Appeals of Alabama; July 13, 2018; Alabama; State Appellate Court
In February 2017, I.W.M. applied for nursing-home benefits for his wife, J.C.M., from the Alabama Medicaid Agency, which denied the request on July 5, 2017, following a spousal-resource assessment. J.C.M. sought judicial review of this decision in the Montgomery Circuit Court, where the trial court waived the cost bond. Medicaid subsequently moved to dismiss the petition and to vacate the bond waiver, but the trial court denied this motion on April 20, 2018, and appointed Micheal Jackson as Special Master to handle the case. The Special Master was tasked with hearing motions, making findings of fact, and reporting to the court, with compensation arrangements to be determined between parties or by the court if necessary. Medicaid filed a motion on May 1, 2018, to vacate the referral order, arguing that there was no basis for the referral and that the trial court could not compel the state to pay the special master. The trial court denied this motion on May 7, 2018. Medicaid then petitioned for a writ of mandamus against the referral order on May 11, 2018, within the 42-day window allowed, prompting the court to stay proceedings and request an answer to the petition. In its argument, Medicaid contended that the referral order was overly broad and violated Rule 53(b) of the Alabama Rules of Civil Procedure, which states that references to masters should be exceptional and only made under specific conditions. Medicaid cited a previous case, Ex parte Alabama State Personnel Board, where the Alabama Supreme Court mandated the vacation of a similar referral order, emphasizing that special masters should assist rather than replace judges and that their authority must be clearly defined. The court's previous ruling reiterated that exceptional conditions must justify the appointment of a special master. No exceptional condition necessitating the appointment of a special master has been identified in this case. The action is an administrative appeal governed by Ala. Code 1975, § 41-22-20, part of the Alabama Administrative Procedure Act (AAPA). Under the AAPA, circuit courts must review agency decisions without a jury, treating agency orders as prima facie just and reasonable, and cannot substitute their judgment on factual matters. The dispute involves J.C.M.'s claim that Medicaid wrongfully denied her nursing-home benefits, arguing her one-half interest in certain property should be excluded as an asset under Medicaid regulations. The case's complexity does not warrant a special master, and the referral order is deemed overly broad, improperly delegating authority without specific limitations. According to precedent, referrals to special masters should be rare and only in exceptional circumstances, considering the potential for increased costs and delays. The trial court's referral order is thus vacated, and the petition is granted. Discussion of Medicaid's argument regarding the payment of the special master's fees is precluded by this conclusion.