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Supreme Court rules in blame-shifting evidence, Medicaid reimbursement cases

[JURIST] The US Supreme Court [official website; JURIST news archive] ruled Monday in three cases, including Holmes v. South Carolina [Duke Law case backgrounder; JURIST report], 04-1327, where the Court struck down a South Carolina rule which prevented Holmes from introducing evidence that a third party committed the crimes for which he was on trial. The South Carolina Supreme Court upheld [opinion] a trial court ruling that Holmes could not introduce evidence of third-party guilt when the prosecution introduced strong forensic evidence indicating the defendant's guilt, because the third-party evidence would be insufficient to create a reasonable inference of the defendant's innocence. In Justice Alito's first opinion on the bench, the Court overturned the decision, holding that the rule was arbitrary and violates the defendant's constitutional right to have "a meaningful opportunity to present a complete defense." Read the Court's unanimous opinion [text]. AP has more.

In Arkansas Department of Human Services v. Ahlborn [Duke Law case backgrounder], 04-1506, the Court held that federal laws governing Medicaid [HHS materials] do not authorize a state agency to assert a lien on a Medicaid recipient's personal injury settlement in an amount equal to the amount of benefits paid on the recipient's behalf when a lesser amount has been designated as compensation for medical care. Under an Arkansas law requiring Medicaid recipients to assign to the Arkansas Department of Human Services their "right to any settlement, judgment, or award" they receive from third parties "to the full extent of any amount which may be paid by Medicaid for the benefit of the applicant," the ADHS attempted to recover the full $216,000 it paid on Ahlborn's behalf from a $550,000 settlement Ahlborn received to cover medical expenses, loss of earnings, and pain and suffering. The Court affirmed the Eighth Circuit decision [PDF text] in the case, holding that the federal anti-lien statute prohibits the ADHS from asserting a lien on the portion of the settlement not meant to cover medical expenses. Read the Court's unanimous opinion [text], per Justice Stevens.

In the third case decided Monday - the Anna Nicole Smith case - the Court held that federal courts can in some cases decide disputes which involve state probate laws [JURIST report]. Also Monday, the Court agreed to hear Ornaski v. Belmontes, where it will clarify the constitutionality of a California jury instruction in death penalty cases. SCOTUSblog has more. Read the Court's full Order List [PDF text].

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