Linton v. Commissioner of Health and Environment

Tennessee (defendant) adopted a policy certifying only a portion of nursing-home beds as available to Medicaid patients; Mildred Linton (plaintiff), a Medicaid patient and nursing-home resident, was involuntarily transferred facilities as a result. Linton sued alleging, among other claims, that the policy had an unjustifiable disparate racial impact — although Black residents made up 39 percent of Medicaid patients, they accounted for only 15 percent of those who successfully gained access to Medicaid-covered nursing-home services. Tennessee attributed this disparity to minority self-selection, citing reliance on extended family, lack of transportation, and fear of institutional care.