In a recent opinion, an appellate court in Minnesota held that county officials were not liable for incorrectly telling a Medicaid applicant that his estate would not be subject to a Medicaid lien because the applicant could have hired a lawyer to learn the correct information. Benigni v. St. Louis County (Minn. Ct. App., No. A15-1154, June 13, 2016).

In 2004, Kenneth Benigni applied for Medicaid benefits from the Lake Superior Community Health Center in Duluth, Minnesota. The caseworker assisting him removed a six-page section of the Medicaid application form without showing it to the applicant. This section of the form included information about the state’s right to place a lien on Mr. Benigni’s property to recoup all monies paid by Medicaid for medical assistance provided to Mr. Benigni.

Mr. Benigni received Medicaid renewal forms in 2005 and 2007 that included information about the lien. He asked county officials about the lien and they told him, incorrectly, he would not be subject to any lien. In 2007, after requesting additional information, Mr. Benigni discovered that the Medicaid benefits were subject to recovery through liens and estate claims on his property. As a result, Mr. Benigni cancelled his Medicaid benefits. Five years later, Mr. Benigni learned that his estate was subject to a $20,000 lien as a result of the Medicaid benefits he received.

Mr. Benigni sued the county, arguing that the county officials supplied false information to him about whether a Medicaid lien could be placed on his property. The trial court granted summary judgment to the county, and Mr. Benigni appealed.

The Minnesota Court of Appeals affirmed the trial court’s order dismissing Mr. Benigni’s complaint.  The appeals court held that, unless they are learned in the field or have a fiduciary relationship with the person to whom they provide information, county officials are not liable for supplying incorrect information to the public if the information is readily available to the public from other sources. In this case, the appeals court ruled that the county officials were not learned in the field, they did not have a fiduciary relationship with Mr. Benigni, and Benigni could have learned the correct information about Medicaid liens by seeking legal advice from an attorney.

The case is annexed here – Benigni v. St. Louis County

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