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Martin v. City of Rochester8/15/2000
The state claims that the district court erred in finding that Minnesota's medical-assistance lien provision is in conflict with federal Medicaid law. Because we find that compliance with both state and federal law is possible, we reverse.
FACTS
Troy Hoff suffered brain damage in a motor-vehicle accident and was permanently disabled. Respondent Joan Martin, Hoff's mother, applied for and received medical assistance on Hoff's behalf and, under Minnesota statutes, assigned Hoff's rights to any insurance recovery to appellant State of Minnesota.
Respondent then brought a personal-injury action against the City of Rochester and others on behalf of her son. Under Minn. Stat. §á256B.015, the state filed a lien against this action to secure reimbursement of medical expenses it had paid to treat his injuries. The district court held that Minn. Stat. §á256.015 was invalid because it conflicted with 42 U.S.C. §§á1396k and 1396p, and, thus, the federal statute preempted the state statute. On appeal, the state contends there is no preemption and the federal statute does not bar the state from placing a lien on the tort recovery.
ISSUES
I. Does federal law allow the state to impose a lien on a third-party tort settlement to secure reimbursement of medical assistance paid?
II. Is this court required to strike appellant's appendix as outside the record?
ANALYSIS
I.
The preemption doctrine stems from the Supremacy Clause of the United States Constitution, which provides that the laws of the United States "shall be the supreme Law of the Land * * * any Thing in the Constitution or Laws of any State to the Contrary notwithstanding." U.S. Const. art. VI, cl. 2. According to the preemption doctrine, conflicts between federal and state law are to be resolved in favor of federal law. Fidelity Fed. Sav. and Loan Ass'n v. de la Cuesta, 458 U.S. 141, 152-53, 102 S.áCt. 3014, 3022 (1982).
Minnesota's three-part analysis to determine whether a federal statute preempts operation of a state statute looks at whether: (1) compliance with both the federal and state provisions is impossible; (2) preemption is express and unequivocal in the language of the federal statute; and (3) congressional preemptive intent is implicit in the overall scheme of federal and state regulation. Highland Chateau, Inc. v. Minnesota Dep't of Pub. Welfare, 356 N.W.2d 804, 809-10 (Minn. App. 1984), review denied (Minn. Feb. 6, 1985). The question in this case is whether compliance with both federal and state law is possible.
The relevant federal statute provides:
No lien may be imposed against the property of any individual prior to his death on account of medical assistance paid or to be paid on his behalf under the State plan *á*á* . 42 U.S.C. §á1396p(a)(1) (1994).
Another federal provision, however, directs the states to require that an individual receiving medical assistance must assign his rights to "payment for medical care from any third party." 42 U.S.C. §á1396k(a)(1)(A) (1994).
The state lien statute provides that the state shall have a lien for the cost of medical care against "any and all causes of action." Minn. Stat. §á256B.015 (Supp. 1999). Respondent asserts that this provision violates the foregoing federal statute because it provides for a lien against the property of Hoff before his death. Respondent argues that, although the state may seek reimbursement directly from a
third party who is legally liable for the injuries resulting in medical care, it may not proceed as it did in the instant case by asserting a lien against the recipient
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