May 12

Court Must Open Medicaid Recipient’s Estate Before Ruling on Validity of Estate Recovery Claim

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A Missouri appeals court reverses a lower court’s decision to deny the state’s Medicaid recovery claim against a Medicaid recipient’s estate because the court was prohibited from ruling on the validity of the claim at the initial hearing to open the estate. Estate of Tiefenbrunn (Mo. Ct. App., No. SD34045, April 6, 2016).

Shirley Tiefenbrunn executed a beneficiary deed that left her house to her daughter and son-in-law. Ms. Tiefenbrunn began receiving Medicaid benefits, and the state filed a lien on the property. After Ms. Tiefenbrunn died, the state filed a release of the lien, stating that Ms. Tiefenbrunn no longer owned the property.

A year after Ms. Tiefenbrunn died, the state filed a petition to open Ms. Tiefenbrunn’s estate and to recover Medicaid benefits paid on her behalf. Ms. Tiefenbrunn’s daughter opposed the petition, arguing that the release of the lien waived the state’s claim. The trial court entered judgment denying the state’s claim. The state appealed.

The Missouri Court of Appeals reverses, holding that the trial court did not have discretion to deny the state’s petition. According to the court, when an interested party timely files a petition to open the estate, the trial court is required to grant the petition and is prohibited from determining the validity of the claim at the initial hearing.

For the full text of this decision, go to: