Injury Laws: Yes, your wife is part of your family (plus special bonus astronomy talk)

From the 6th Circuit’s decision last week in Wheaton v. McCarthy, some excerpts, including all the astronomical references and the one Ukrainian one (some paragraph breaks added):

Ask 100 Americans whether a 74 year-old man’s “family” includes his wife who lives with him, and every one of those Americans will likely answer yes. But here the Ohio Department of Medicaid answered no, with the result that it denied Joe Turner’s application for benefits under the Medicaid Act. That Act requires States who receive Medicaid funding to provide certain low-income Medicare beneficiaries with financial assistance to help pay their out-of-pocket Medicare costs. Under federal law, to determine whether a beneficiary is eligible for such assistance, the State must compare the beneficiary’s income to the federal poverty line “for a family of the size involved.” The larger the size of the “family involved,” the greater the income a beneficiary can earn and still be eligible for assistance.

In making this comparison, however, Ohio generally does not count a Medicare beneficiary’s spouse as a member of his “family.” The question presented is whether Ohio’s interpretation of the word “family,” as applied here, is a permissible one. We hold it is not, and reverse the district court’s judgment to the contrary… .

To ask whether the ordinary meaning of “family” includes a person’s resident spouse, one might say, is like asking whether our solar system includes the planet Venus; but we proceed with the analysis nonetheless… .

Reasonable people might disagree, as a matter of ordinary usage [and relying on dictionary definitions omitted here -EV], as to whether the term “family” should include adult children who live with their parents, or a 17 year-old child who does not, or nieces and nephews who live with their aunts and uncles. Thus, as a practical matter, it is likely up to the State whether to count those persons as part of the beneficiary’s family under §§ 1396d(p)(2) and 1396a(a)(E)(10).

But that does not mean the term family is ambiguous as applied here… . The term “planet” might be ambiguous as applied to Pluto, but is clear as applied to Jupiter. And though there might be some ambiguity in 2015 as to whether Ukraine’s borders encompass the Crimean Peninsula, there is no doubt that Kiev lies within them. So too here: whatever ambiguity the “persons living under one roof” or “basic unit of society” definitions might have at the margins, there is no doubt that, under either definition, a person’s family includes her resident spouse… .

The State also argues that the relevant term here is not simply “family,” but “family of the size involved”; and in the State’s view that phrase does not have any ordinary meaning, which means the State can define it in whatever way makes good policy sense. The word “involved,” especially, the State seems to regard as an interpretive wormhole, whose supposed ambiguity leads to a galaxy of unfettered agency discretion.

But the meaning of that word and this phrase as a whole is not nearly so abstruse as the State suggests. The word “involved” simply — and we think clearly — directs the State to consider the federal poverty line for the beneficiary’s family, rather than someone else’s. And the meaning of “size” is disputed by no one. Thus, as applied here, the meaning of this phrase is just as clear as the meaning of “family” — which as applied here is clear enough to enforce its core meaning rather than a conflicting State one… .

Thanks to the Institute for Justice’s Short Circuit for the pointer.