Clarifying Mootness of Prospective Medicaid Claims upon Plaintiff Death and Qualified Immunity Standards

Introduction

The United States Court of Appeals for the Tenth Circuit’s decision in Lamle v. Eads (No. 24-6124, Apr. 9, 2025) addresses two critical issues in civil rights and administrative law: (1) when a claim for prospective injunctive relief becomes moot upon the death of plaintiffs and the denial of administrative benefits, and (2) the contours of qualified immunity for a state‐level actor who participates in the processing of Medicaid applications. Plaintiffs‐appellants Penelope Lamle and Maxine Houston (later substituted by their estates) challenged the Oklahoma Department of Human Services and the Oklahoma Health Care Authority for alleged delays and improper questioning in the Medicaid application process, and sued Susan Eads in her individual capacity for directing those questions. The district court dismissed all claims with prejudice; on appeal, the Tenth Circuit clarified the law of mootness and affirmed qualified immunity for the individual defendant.

Summary of the Judgment

The Tenth Circuit held:

Claims for a prospective injunction (ordering the agencies to reprocess and pay benefits) became moot when the applicants died and their applications were denied. Mootness is a jurisdictional bar, so the district court’s dismissal should have been without prejudice rather than with prejudice.
Defendant Susan Eads, sued in her individual capacity for directing impermissible questions and threatening denial of benefits, was entitled to qualified immunity because the plaintiffs failed to identify any controlling precedent or clearly established law showing that her conduct was unlawful.
The case was remanded to vacate the with‐prejudice dismissal of the injunctive‐relief claim and to enter dismissal without prejudice on mootness grounds; the dismissal of the damages claim against Eads remained with prejudice.

Analysis

Precedents Cited

Keller Tank Servs. II v. Comm'r of Internal Revenue (854 F.3d 1178, 1193 (10th Cir. 2017)): established that a case is moot if the requested relief cannot have a real‐world effect.
Lancaster v. Sec’y of the Navy (109 F.4th 283, 289 (4th Cir. 2024)): emphasized that mootness depends on the specific relief sued for in the complaint.
Harris v. City of Houston (151 F.3d 186, 190–91 (5th Cir. 1998)): held that mootness of one form of injunctive relief is not cured by the possibility of alternative relief not pleaded in the complaint.
Williams v. McClellan (569 F.2d 1031, 1032–33 (8th Cir. 1978)): per curiam decision finding a termination‐request injunction moot upon termination.
Melville v. Cuyahoga Cnty. Bd. of Elections (462 F.2d 486, 487 (6th Cir. 1972)): per curiam on mootness where no declaratory relief was sought.
Estate of Schultz v. Brown (846 F. App’x 689, 693–95 (10th Cir. 2021)): directly parallels Lamle v. Eads by holding that a decedent’s death renders injunctive relief moot.
Brown v. Buhman (822 F.3d 1151, 1179 (10th Cir. 2016)): instructs that jurisdictional dismissals for mootness must be without prejudice.
Robbins v. Okla. ex rel. Dep’t of Human Servs. (519 F.3d 1242, 1249 (10th Cir. 2008)): set out the standard for plausibly pleading a denial of clearly established rights under qualified immunity analysis.
Colbruno v. Kessler (928 F.3d 1155, 1160–61 (10th Cir. 2019)) and District of Columbia v. Wesby (583 U.S. 48, 63 (2018)): reiterated that qualified immunity protects officials unless “every reasonable official” would know conduct is unlawful.
Rose v. Brown (14 F.4th 1129 (10th Cir. 2021)): held only that a genuine dispute existed over Medicaid eligibility, but did not clearly establish a right preventing state officials from questioning applicants.

Legal Reasoning

Mootness of Prospective Relief: Under Article III, federal courts can only decide ongoing “cases or controversies.” When Ms. Lamle and Ms. Houston died and their Medicaid applications were denied, there was no longer any live dispute over the relief they sought—namely, certification of eligibility and payment of benefits. Even though the estates argued for a reprocessing injunction, the complaint had not pled that form of relief, and a court cannot grant a remedy beyond the scope of the pleadings. Consistent with settled circuit precedent, the Tenth Circuit held that such claims must be dismissed without prejudice (not with prejudice) where mootness intervenes.

Qualified Immunity for a Non‐Decisionmaker: The plaintiff must identify binding authority that clearly establishes the unlawfulness of an official’s specific actions. Here, the estates pointed solely to directives by Ms. Eads to ask additional questions and to warn of denial if unanswered. No Supreme Court or Tenth Circuit decision has ever held that posing eligibility questions or warning applicants of consequences violates constitutional rights. Accordingly, Ms. Eads could not have known her conduct was unlawful, and she enjoys qualified immunity, requiring dismissal with prejudice as to her.

Impact

This decision reinforces and clarifies two areas of law:

Death‐Mootness Doctrine: Any injunctive or prospective relief claim is extinguished if the plaintiff dies or otherwise loses the continuing injury necessary for relief. Practitioners must plead all forms of prospective relief they seek, because unpleaded remedies cannot be considered once the case goes moot.
Qualified Immunity Boundaries: Officials who participate in administrative processes—short of making final decisions—are insulated from damages claims absent a binding precedent that proscribes their specific conduct. This decision underscores the high bar plaintiffs must meet to overcome qualified immunity.

Complex Concepts Simplified

Mootness: A case is moot when events occur that prevent a court from granting any effectual relief. Once the requested relief can no longer change the parties’ rights, the court must dismiss the case.
Prospective vs. Retrospective Relief: Prospective relief (e.g., injunctions ordering future action) survives only if there is an ongoing injury. Retrospective relief (e.g., damages) must overcome sovereign‐immunity defenses like the Eleventh Amendment.
Qualified Immunity: A doctrine protecting government officials from personal liability unless they violate a right that was clearly established at the time.
Clearly Established Law: An individual right is “clearly established” only if existing precedent—preferably from the Supreme Court or the controlling circuit—has defined the right with reasonable specificity.

Conclusion

Lamle v. Eads cements the principle that a decedent’s claim for prospective relief becomes moot upon death and requires a without-prejudice dismissal, while reaffirming the stringent standards for overcoming qualified immunity. Going forward, litigants will need to ensure that all desired forms of relief are expressly pled and be prepared to identify controlling precedent when suing state actors for constitutional violations in administrative proceedings.