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Federal Appeals Court Upholds Ruling That Florida's Medicaid Termination Notices Were Unconstitutional, Keeping Income Cutoffs on Hold

The Florida Press Newsroom5 min read
Federal Appeals Court Upholds Ruling That Florida's Medicaid Termination Notices Were Unconstitutional, Keeping Income Cutoffs on Hold
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A federal appeals court has upheld a ruling that Florida violated the constitutional due process rights of hundreds of thousands of low-income Medicaid enrollees. The court found the state's termination notices so confusing that recipients, and in at least one case a state employee, could not tell whose coverage was ending or why. The decision keeps in place an injunction that bars the state from cutting off family-related Medicaid coverage over income until its notices meet constitutional standards.

A three-judge panel of the 11th U.S. Circuit Court of Appeals issued the 23-page opinion last week, written by Judge Barbara Lagoa. It affirms a January permanent injunction from U.S. District Judge Marcia Morales Howard in Jacksonville. The class action covers nearly 500,000 people. About 2.5 million Floridians are enrolled in family-related Medicaid, the coverage for children, pregnant women, and parents and caretakers of minors.

What the appeals court decided

The case centered on whether a Medicaid termination notice has to tell people the facts behind the decision: how many people the state counted in their household, how much income it counted, which eligibility category it used and which income limit it applied. Florida's notices did not.

Lagoa wrote that a notice that leaves out which premise the Department of Children and Families relied on fails the recipient, because without that information "the recipient does not know what objection to make," according to the Florida Trib, which first reported the ruling. The panel found Howard did not err in concluding that the notices gave enrollees too little explanation to contest a termination. It also rejected the state's argument that its call center filled the gap, according to the Trib's report.

The panel drew one line in the state's favor. It said complaints about the layout of the notices "do not create a second constitutional claim called 'structure,'" according to the Trib. The core holding is about missing information, not design. Even so, the court found the documents confusing and contradictory. One notice listed a child as both ineligible and eligible in different sections.

The families behind the lawsuit

The Florida Health Justice Project and the National Health Law Program filed the class action in August 2023, months after a COVID-era federal rule that kept people on Medicaid expired on March 31, 2023. Florida then resumed eligibility reviews and sent hundreds of thousands of termination notices, many based on income.

The lead plaintiff, a Jacksonville mother identified in court as Chianne D., received an 11-page notice that gave conflicting answers about whether she and her newborn son would keep coverage. A DCF employee wrongly told her the baby was losing coverage, according to the Trib. The state later determined that her own coverage had been wrongly terminated, the Florida Phoenix reported.

Another plaintiff, identified as A.V., lost coverage after DCF counted six people in her household instead of eight. That lowered her income limit from $6,110 to $4,868 a month. Her notice disclosed neither figure, so she had no way to know the state had miscounted her family.

How the case got here

Howard ruled on Jan. 6, 2026, that the notices violated due process. She found the state had known since at least 2018 that they were inadequate, according to a WGCU report from July. She did not order coverage automatically restored for everyone in the class. Instead, she barred new income-based terminations until the notices were fixed. She also required corrective notices to people already cut off, explaining the reason, the household size and income the state used, and how to appeal.

The state appealed in February. In April, the 11th Circuit denied Florida's request to put the injunction on hold while the appeal proceeded, according to the Florida Health Justice Project. DCF paused income-based terminations as of Feb. 23, and by May 1 the state had sent roughly 1 million corrective notices, WGCU reported. Lynn Hearn, legal director of the Florida Health Justice Project, said the number of people reached is lower than the number of notices because households received duplicates.

The trial record also described a strained call center. In April 2024, DCF blocked 744,000 calls, or 53.9% of requests, before they reached the queue for a live agent, according to the Trib. The judge found the center had dropped as many as a third of calls in one month.

At oral argument in August, the state's lawyer, Andy Bardos, argued that due process requires a notice to state only the intended action, its date and the reason. Judges on the panel pushed back. Judge Adalberto Jordan told Bardos "This is pretty bad," the Phoenix reported, and Judge Robin Rosenbaum asked, "What is the whole point of hiding this information?" according to the Trib.

What it means for Floridians on Medicaid

For families in the class, the practical effect is that the injunction stays. Florida cannot end anyone's family-related Medicaid over income unless the notice states that coverage will end, names each person losing it and explains why, with the figures used to reach the decision.

Hearn told the Trib, "This is truly great news for all Medicaid recipients." She told the Phoenix, "The good news is, going forward it is crystal clear that this is the standard for all Medicaid termination notices."

Advocates see wider stakes. The National Health Law Program said the ruling matters as states carry out eligibility changes under the One Big Beautiful Bill Act, the 2025 federal law that tightens Medicaid rules. Hearn told the Trib that new notices Florida is sending about federal limits on Medicaid for immigrants also cite wrong reasons and leave out information about immigration status. She also said DCF's caseworker staffing, training and processing times remain problems.

The state revised its notices while the appeal was pending, according to Hearn. The computer system that produces them is run under a state contract with Deloitte Consulting. As of July, WGCU reported, it had not been permanently repaired, and the state estimated a four- to six-month timeline.

What's next

Florida's Agency for Health Care Administration and DCF did not respond to requests for comment from either outlet. It is unclear whether the state will ask the U.S. Supreme Court to review the decision before Gov. Ron DeSantis leaves office in early January, when Governor-elect Byron Donalds takes over. If the state does not seek further review, the injunction remains the governing standard, and any income-based terminations will depend on notices that meet the requirements Howard set and the appeals court upheld.

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