Medicaid repayment from settlements
Wos v. E. M. A., a Minor
In brief
North Carolina could not use its automatic one-third rule: the Supreme Court agreed with the appeals court that federal law bars it.
- Where it stands
- Decided
Decided 6-3 · March 20, 2013 · Opinion by Justice Breyer
- What it’s about
- North Carolina sought to recover Medicaid costs from E.M.A.’s injury settlement under a state rule that automatically counted one-third of the settlement as medical expenses.
- Who it affects
- North Carolina cannot use its automatic one-third rule to decide how much of an injury settlement counts as medical expenses for Medicaid repayment.
Summary: written with AI from the case record.
What it's about
The Supreme Court agreed with the Fourth Circuit that federal Medicaid law bars that fixed presumption.
North Carolina had paid E.M.A.’s medical expenses through Medicaid and sought repayment from her injury settlement.
The dispute concerned how North Carolina could seek repayment of Medicaid expenses after a patient received money in an injury settlement.
Question presented
Does federal Medicaid law prohibit North Carolina's third-party liability statutes from mandating reimbursement of medical expenses from a patient's lump-sum settlement?
What the Court decided
Holding
The federal anti-lien provision pre-empts North Carolina’s irrebuttable statutory presumption that one-third of a tort recovery is attributable to medical expenses. 674 F. 3d 290, affirmed.
- Result
- Affirmed
The Court's reasoning
The Court said federal Medicaid law bars North Carolina’s rule because it automatically labeled one-third of an injury settlement as medical expenses without allowing that assumption to be challenged.
The vote
From the opinions
“The Court’s reading of the Act, while plausible, is not compelled by the statutory text or our precedent.”
What's next
The Fourth Circuit’s ruling remains in place, and North Carolina cannot use the automatic one-third presumption to set Medicaid repayment from injury settlements.
Documents
Opinions
Audio
Docket activity
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AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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Case data updated: summary, question_presented, generation_metadata
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Audio Recording added: Oral Arguments - Delia
Opinion added: Wos
More questions
- Why did Justice Breyer agree?
- He said his agreement rested in part on the federal Medicaid agency reaching the same conclusion and having expertise in administering the program.
- What did Chief Justice Roberts argue?
- He said federal law did not tell states how to divide a settlement and argued that states should have more flexibility.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.