## Facts

- Pennsylvania participated in the federal–state Medicaid program under Title XIX of the Social Security Act.
- State regulations provided Medicaid payment for eyeglasses only when used to treat “eye disease or pathology.”
- Indigent Medicaid-eligible persons who needed eyeglasses to correct refractive error, but had no eye disease or pathology, were denied coverage under the regulations.
- Plaintiffs presented medical evidence that refractive error without disease can cause serious visual impairment and that eyeglasses commonly correct refractive error rather than treat most eye diseases.
- Plaintiffs brought a class action under 42 U.S.C. § 1983 asserting Fourteenth Amendment due process and equal protection violations and a pendent claim that the regulations conflicted with Title XIX and federal Medicaid regulations.
- The district court found the constitutional claims sufficiently substantial to support jurisdiction and granted summary judgment for plaintiffs on the statutory ground, enjoining enforcement of the restrictive eyeglass regulations.

## Issues

1. Whether the plaintiffs’ constitutional claims were so insubstantial that federal jurisdiction was lacking, preventing adjudication of the pendent statutory Medicaid claim.
2. Whether Pennsylvania’s Medicaid regulation limiting eyeglass coverage to treatment of eye disease or pathology, rather than medical necessity for refractive error, conflicted with Title XIX and implementing federal regulations requiring reasonable standards for the extent of covered services.

## Decision

- The Third Circuit held the constitutional claims were not so insubstantial as to defeat jurisdiction under the standard stated in Hagans v. Lavine.
- The court affirmed the district court’s use of constitutional avoidance by resolving the case on the pendent statutory claim without reaching the constitutional merits.
- The court affirmed the injunction, holding Pennsylvania’s etiology-based limitation on eyeglass coverage was inconsistent with Title XIX and federal Medicaid requirements.

## Legal Principles

- Federal jurisdiction exists in welfare-benefits litigation when constitutional claims are not “so insubstantial, implausible, foreclosed, or devoid of merit” as to fail to present a federal controversy; once jurisdiction exists, a court may decide a dispositive statutory ground without reaching constitutional questions.
- Participating states have discretion over the amount, duration, and scope of Medicaid services, but that discretion is constrained by Title XIX and federal regulations.
- Medicaid coverage standards for services must be reasonable and consistent with the objectives of Title XIX; a categorical exclusion that turns on etiology rather than medical necessity may violate those requirements.

## Conclusion

The Third Circuit upheld federal jurisdiction and invalidated Pennsylvania’s Medicaid rule that limited eyeglasses to cases of eye disease or pathology, concluding that Title XIX and its regulations require reasonable, medically grounded coverage standards rather than an etiology-based exclusion that denies medically necessary eyeglasses for refractive error.


White v. Beal, 555 F.2d 1146 (3d Cir. 1977)