Arkansas Dept. of Health & Human Services v. Ahlborn
In Arkansas Dept. of Health & Human Services v. Ahlborn (547 U.S. 268 ) the plaintiff was seriously and permanently injured in a motor vehicle accident and the Arkansas Department of Health and Services(ADHS) provided substantial medical care for her. She sued the defendants and ADHS intervened to assert a lien on any recovery plaintiff might obtain. The case settled for $ 550,000 but the settlement was not allocated among damage categories. ADHS claimed its entire lien was recoverable under Arkansaslaw, whether the plaintiff's recovery was allocated for medical costs, lost wages, pain and suffering or anything else. The Supreme Court found that the federal anti-lien provisions under the Medicaid law limited the states to recovery from only that portion of a verdict or settlement that was attributable to past medical expenses.
Ahlborn appears to have overruled a series of New York cases that held the entire recovery by a plaintiff was available to satisfy a Medicaid lien (see Gold v. United Health Servs. Hosps., Inc., 95 N.Y.2d 683 ; Calvanese v. Calvanese, 93 NY2d 111 ; Cricchio v. Pennisi, 90 NY2d 296 ).