Mootness of Medicaid Injunction Claims Post-Applicant Death and Qualified Immunity for State Officials

Introduction

In Lamle v. Eads, 10th Cir. (Apr. 9, 2025), the Tenth Circuit addressed two intertwined issues in the context of Medicaid-application litigation: (1) when requests for prospective injunctive relief become moot following the death of applicants and denial of benefits and (2) the scope of qualified immunity for a private attorney directing a state agency’s processing of Medicaid applications.

Plaintiffs–Appellants Joshua Lamle and Lexy Jobe (co-personal representatives of the estate of Penelope Lamle) and Dal Houston (personal representative of the estate of Maxine Houston) challenged the Oklahoma Department of Human Services (OKDHS) and Oklahoma Health Care Authority (OHCA) procedures—and the role of attorney Susan Eads—in requesting additional financial information from elderly applicants. After the applicants died and the state agencies denied their applications, the district court dismissed their claims with prejudice. On appeal, the Tenth Circuit considered mootness of the injunctive claims and whether Eads was entitled to qualified immunity on the personal-capacity damages claim.

Summary of the Judgment

The Tenth Circuit reached two principal conclusions:

Mootness: All claims for prospective relief (an order compelling expedited processing and payment of benefits) became moot when the applicants died and their applications were denied. Because mootness deprives the court of jurisdiction, the proper disposition is dismissal without prejudice (not with prejudice).
Qualified Immunity: On the individual-capacity claim against attorney Susan Eads, the plaintiffs failed to identify any “clearly established” constitutional right violated by Eads’s instructions to OKDHS. Accordingly, Eads is immune from damages, and that portion of the dismissal with prejudice was affirmed.

Analysis

1. Precedents Cited

Keller Tank Servs. II v. Commissioner, 854 F.3d 1178 (10th Cir. 2017): Defined mootness as relief that “will not have some effect in the real world.”
Lancaster v. Secretary of the Navy, 109 F.4th 283 (4th Cir. 2024): Held mootness hinges on the relief sought in the complaint, not hypothetical remedies.
Harris v. City of Houston, 151 F.3d 186 (5th Cir. 1998); Williams v. McClellan, 569 F.2d 1031 (8th Cir. 1978); Melville v. Cuyahoga Cnty. Bd. of Elections, 462 F.2d 486 (6th Cir. 1972): Contributed to the proposition that a case is moot when the form of relief requested can no longer provide meaningful relief.
Estate of Schultz v. Brown, 846 F. App’x 689 (10th Cir. 2021): Factually analogous unpublished decision holding that a decedent’s death mooted a claim for procedural fairness in Medicaid review, requiring dismissal for lack of continuing injury.
Brown v. Buhman, 822 F.3d 1151 (10th Cir. 2016): Confirmed that mootness is jurisdictional and that dismissals on mootness grounds must be without prejudice.
Robbins v. Oklahoma ex rel. Dep’t of Human Servs., 519 F.3d 1242 (10th Cir. 2008); Colbruno v. Kessler, 928 F.3d 1155 (10th Cir. 2019); District of Columbia v. Wesby, 583 U.S. 48 (2018): Set forth the qualified-immunity standard—requiring a “clearly established” right that “every reasonable official would understand.”
Rose v. Brown, 14 F.4th 1129 (10th Cir. 2021): Addressed the rights of Medicaid applicants but did not recognize a clearly established right violated by an attorney’s participation in processing questions.

2. Legal Reasoning

Mootness of Prospective Relief: Under Article III, courts may only decide live controversies. Here, the amended complaint sought an injunction requiring OKDHS and OHCA to (a) certify the applicants’ eligibility within 45 days and (b) pay benefits. Once the agencies had denied benefits and the applicants died, no order could alter that outcome. The applicants’ estates conceded that retrospective relief would be barred by the Eleventh Amendment. The panel therefore held that the district court lacked jurisdiction over those requests and that the dismissal must be without prejudice.

Qualified Immunity: Even assuming Eads had directed impermissible questions and threatened denial, the estates could not point to any Supreme Court or Tenth Circuit precedent clearly establishing that such conduct violated constitutional rights. Absent on-point authority or a consensus of persuasive cases, Eads’s actions fell within her official duties and she was immune from suit for damages in her personal capacity.

3. Impact

This decision clarifies two important principles in federal Medicaid litigation:

Mootness & Dismissal Procedure: Plaintiffs seeking prospective injunctive relief must maintain a live controversy through final judgment. Should such relief become futile—due to death, an administrative denial, or other events—the suit should be dismissed without prejudice as moot.
Qualified Immunity for Third-Party Actors: Attorneys or consultants directing state entities in benefit-processing questions enjoy qualified immunity unless plaintiffs identify a clearly established constitutional violation. This raises the bar for personal-capacity suits against non-state-officeholders participating in administrative decision-making.

Complex Concepts Simplified

Mootness: If an event eliminates the ongoing effect of a requested remedy—like a party’s death or final administrative denial—the court no longer has a live case or controversy and must dismiss.
Prospective vs. Retrospective Relief: Prospective relief orders a change in future conduct (e.g., reprocessing an application). Retrospective relief seeks to remedy past harm (e.g., payment for benefits already withheld). States often have sovereign immunity against retrospective relief under the Eleventh Amendment.
Qualified Immunity: Government officials (and those acting at their direction) cannot be sued for damages unless the plaintiff shows the official violated a constitutional right that was clearly established at the time of the action.
Clearly Established Law: A right is clearly established when controlling precedents or a consensus of persuasive decisions would place the unlawful nature of the conduct beyond debate for every reasonable officer.

Conclusion

Lamle v. Eads reinforces procedural safeguards for federal courts adjudicating Medicaid disputes. It affirms that courts must dismiss injunction claims when their grant would no longer produce real-world relief and that such dismissals should be without prejudice. The decision also delineates the protective scope of qualified immunity for private actors who assist state agencies in benefit determinations, emphasizing the necessity of on-point authority to overcome immunity. Together, these principles will guide practitioners in framing viable claims and assist courts in managing the jurisdictional boundaries of federal Medicaid litigation.