In re The Estate of Michael Patrick Smith v. Heckler

The Estate of Michael Patrick Smith (plaintiff) sued HHS Secretary Heckler (defendant) on behalf of Colorado Medicaid nursing-home residents, alleging Heckler's compliance review system was improperly "facility-oriented" rather than "patient-oriented," evaluating only physical facilities rather than the actual quality of care residents received; the district court held Heckler's approach did not violate her statutory duty and found Colorado, not Heckler, was the proper defendant for developing and enforcing care standards.