Chianne D v. Weida
Issue: Do Florida’s Medicaid termination notices violate enrollees’ constitutional due process rights?
Background: A group of Medicaid enrollees sued Florida arguing that the state’s notices terminating their coverage violate their due process protections under the U.S. Constitution. They seek reinstatement of benefits for all people whose coverage was unconstitutionally terminated, as well as an overhaul of the state’s termination procedures. The plaintiffs include women in their 12-month postpartum period, children who have gone without regular vaccinations and well child care, and a child with serious chronic health conditions who has experienced adverse health consequences due to foregone care. The case was certified as a class action and a trial was held in summer 2024.
On January 6, 2026, the trial court issued a decision in favor of the Medicaid enrollees, finding that Florida's termination notices violate enrollees' constitutional right to due process. The court found that Florida's termination notices "border on the incomprehensible" resulting in "tremendous confusion, lost time, stress and anxiety." The court emphasized that the defective notices prevented Medicaid enrollees from understanding whether the state's decision to terminate coverage was wrong. "This increases the likelihood that when the State makes an error, which is inevitable in a program of this size and complexity, impoverished parents, children, pregnant women, and infants will lose vital medical benefits for which they are eligible. This causes tremendous harm not only to these individuals, but to society at large."
Going forward, the court permanently enjoined Florida from terminating any Medicaid enrollee's coverage based on the state's conclusion that an enrollee is financially ineligible, without first providing constitutionally adequate notice. The court did not order Florida to automatically re-enroll the nearly 500,000 people who lost coverage after receiving defective notices between March 2023 and March 2024, because the court acknowledged that some of those people may in fact be ineligible. Instead, Florida has 60 days to send corrective notices to the affected people. The new notices must "unambiguously inform[] the intended recipient of the State’s intent to terminate Medicaid benefits, the person or persons whose benefits will be terminated, and detail[] the reasons for that decision as to each person. . . includ[ing] sufficient case-specific information to allow the recipient to assess the accuracy of the State’s decision and decide whether to request a fair hearing.
Current Status: Trial Court Decision Issued
Trial Court Amicus Brief Part I, April 5, 2024
Trial Court Amicus Brief Part II, April 5, 2024
Amici: American Public Health Association and 102 public health deans and scholars
Argument Summary: Due process requires states to provide adequate notice before terminating essential healthcare coverage provided to people in brutal need of medical assistance. Florida’s due process violations harm its most vulnerable residents. Florida’s Medicaid program covers the very poorest children, parents, pregnant people, seniors, and people with disabilities. Florida Medicaid enrollees are some of the most vulnerable populations in the state. Florida has failed to make notices accessible to a low health literacy population. Without Medicaid, Floridians will suffer poor health outcomes. Florida ranks near the bottom nationally in healthcare access, outcomes, and social determinants of health. Existing safety net providers cannot meet the current demand for affordable healthcare for uninsured Floridians, and this problem will grow due to Medicaid coverage loss.
Outside Counsel: Foley Hoag LLP
Related Resources:
Ku L, Musumeci M, Rosenbaum, S. Florida’s Medicaid Unwinding Lacks Fundamental Safeguards And Can Harm Population Health. Health Affairs Forefront. Dec. 1, 2023. https://www.healthaffairs.org/content/forefront/florida-s-medicaid-unwinding-lacks-fundamental-safeguards-and-can-harm-population
Funding Acknowledgment:
Supported by the Commonwealth Fund, a national, private foundation based in New York City that supports independent research on health care issues and makes grants to improve health care practice and policy. The views presented here are those of the authors and not necessarily those of the Commonwealth Fund, its directors, officers, or staff.