A U.S. district court holds that a Medicaid applicant’s § 1983 case against the state for imposing a penalty on the transfer of her home to her caregiver son is barred by the Eleventh Amendment because she seeks retroactive relief from the transfer penalty. Williams v. Connolly (U.S. Dist. Ct., D.N.J., No. 17-1631 (RBK/AMD), Nov. 15, 2017).
John Davis brought his mother, Elizabeth Williams, to live with him in 2012 when she was diagnosed with Alzheimer’s disease. Mr. Davis sold his mother his home and cared for her in the home for three years. In 2014, Ms. Williams deeded the home back to Mr. Davis for $1 and entered a nursing home. In 2015, Ms. Williams applied for Medicaid benefits. The state imposed a penalty period because Ms. Williams had transferred the home to Mr. Davis.
Ms. Williams appealed, arguing that the caregiver exemption applied to the transfer. The state determined that the transfer did not fall within the caregiver exemption because Ms. Williams paid for additional caregivers in addition to her son. Ms. Williams sued the state in federal court under § 1983. The state filed a motion to dismiss.
The United States District Court, District of New Jersey, grants the state’s motion to dismiss, holding that because the claim seeks retroactive relief from the transfer penalty, it is barred by Eleventh Amendment immunity. According to the court, it “cannot require the State of New Jersey to pay benefits it previously determined it would not pay.”
