Judicial Review of Administrative Agency Determinations - Alabama Medicaid Agency v. Marshall


Alabama Medicaid Agency v. Marshall, [Ms. 2150903, Jan. 20, 2017] __ So. 3d __ (Ala. Civ. App. 2017). The Court of Civil Appeals reverses a judgment of the Montgomery Circuit Court reversing a denial by the Alabama Medicaid Agency following an administrative hearing of three separate requests for Medicaid-nursing home benefits where the Montgomery Circuit Court concluded the Agency’s decision denying such benefits was “arbitrary and capricious.” The Court of Civil Appeals makes no determination about the merits of that judgment, but instead reverses on procedural grounds because, under the Alabama Administrative Procedures Act, § 41-22-20(l), Ala. Code 1975, when a trial court reverses an administrative agency determination “the court shall set out in writing, which writing shall become a part of the record, the reasons for its decision.” Citing Alabama Medicaid Agency v. Peoples, 549 So. 2d 504 (Ala. Civ. App. 1989)(Ms. *4), the court concludes that a trial court cannot merely recite the statutory grounds for reversal, but must give in its order specific reasons to support its conclusions. Id.


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