Brisson v. Dep’t of Social Welfare – Case Brief Summary (Vermont)

In Brisson v. Dep't of Social Welfare, 167 Vt. 148, 702 A.2d 405 (1997), a Medicaid recipient was denied coverage for a closed-circuit television (CCTV) to aid her vision.

There, the Secretary refused to provide funding for CCTV because it was not within the scope of covered vision care according to state regulations.

The Court held that the state's refusal to provide coverage for CCTV, while covering lenses and frames, was an impermissible limitation on the amount, scope or duration of the federal purpose in providing vision service because the state failed to provide Medicaid service to those in the greatest need for it. Id. at 151, 702 A.2d at 408.

In other words, the Court found that the state limitations in its vision care service were not rationally related to the federal purpose of providing vision care. Id. at 151-52, 702 A.2d at 408.