Arkansas Department of Health & Human Services v. Ahlborn

In Arkansas Department of Health & Human Services v. Ahlborn, 547 U.S. 268 (2006), the Supreme Court reconciled seemingly conflicting legal stan- dards when it considered whether an Arkansas third-party lia- bility statute permitting the state to claim a right to the entirety of the costs it paid on a Medicaid recipients behalf, regardless of whether that amount exceeded the portion of the recipients judgment or settlement representing past medical expenses, violated federal Medicaid law. (547 U.S. at 278.) In an opinion by Justice Stevens for a unanimous Court, Ahlborn held that Arkansas assertion of a lien on a Medicaid recipi- ents tort settlement in an amount exceeding the stipulated medical-expenses portion was not authorized by federal Med- icaid law; to the contrary, the states attempt to do so was affirmatively prohibited by the general anti-lien provision in 42 U.S.C. 1396p. (Id. at 292. (