Morenz v. Wilson-Coker

In 2004, nursing-home resident Robert Morenz (plaintiff) applied for Medicaid through the Connecticut Department of Social Services (DSS) (defendant). Robert’s wife, Clara Morenz (plaintiff), held his power of attorney and completed the application on his behalf. The application included an assignment of spousal-support rights to the state, purporting to transfer to the state any rights Robert had to support from Clara. Clara also submitted a spousal refusal statement in her own name, stating that she refused to further contribute to Robert’s financial support. When assessing Robert’s Medicaid eligibility, the DSS concluded that the assets in his own name were within an institutionalized spouse’s personal limit for Medicaid eligibility. However, it determined that the assets in Clara’s name exceeded the community-spouse resource allowance (CSRA), or the amount that a community spouse was entitled to retain, by approximately $157,500. The DSS therefore concluded that Robert was not Medicaid eligible until the assets in Clara’s name had been spent down. Robert and Clara sued the DSS to challenge its determination, arguing that because Robert had assigned his spousal-support rights to the state, the DSS could not consider Clara’s assets when determining Robert’s Medicaid eligibility. The district court agreed and granted summary judgment in the Morenzes’ favor. The DSS appealed.