Eleventh Circuit, Chianne D. v. Secretary: Florida's Medicaid termination notices and the Due Process Clause

What happened

On November 4, 2026, the U.S. Court of Appeals for the Eleventh Circuit decided Chianne D. v. Secretary, Florida Agency for Health Care Administration, No. 26-10419, in a published opinion. The panel affirmed a declaratory judgment and permanent injunction entered by the Middle District of Florida after a six-day bench trial. Judge Lagoa wrote the opinion for a unanimous panel of Judges Jordan, Rosenbaum and Lagoa. No judge wrote separately.

The plaintiffs are a certified class of Florida Medicaid enrollees whose coverage the Florida Department of Children and Families (DCF) ended after finding their household income too high, and whose written notices did not identify the income used or the income standard applied. The terminations at issue followed the 2023 to 2024 Medicaid "unwinding," during which, the opinion says, DCF "redetermined the eligibility of more than four million people." After the plaintiffs dismissed a Medicaid Act claim, the case went to trial on a single claim under the Due Process Clause of the Fourteenth Amendment.

What the opinion says

The court applied Mullane v. Central Hanover Bank & Trust Co. (1950), under which notice must be "reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections," and Goldberg v. Kelly (1970), which requires "timely and adequate notice detailing the reasons" for a proposed termination of benefits. In a footnote it stated that Mullane, not the balancing test of Mathews v. Eldridge, "governs the adequacy of notice" in that circuit.

On the notices, the court agreed with the district court's finding that they did not "unambiguously communicate the State's decision to terminate benefits, the reason for that decision, or to whom it applies." It reasoned that financial eligibility turns on countable income, household size (the "Standard Filing Unit"), the eligibility category and the matching income limit, and that "the challenged notices did not disclose enough of those inputs for recipients to check DCF's determination against their own records."

On other sources of information, the court held that the call center, the MyACCESS portal and DCF's public materials did not cure the notices. It noted that DCF's supervisory review explains a decision only after a hearing has been requested, and agreed with the district court that this "comes too late in the process." The court wrote that the district court "did not impose a rule requiring every agency to reproduce every internal calculation in every notice," but applied Mullane and Goldberg to the system proved at trial.

The court also rejected Florida's argument that the district court decided an uncertified "structural claim," holding that how the notices conveyed their information was part of the certified due process question. The injunction it affirmed requires an income-based termination notice to state that coverage will end, identify whose coverage will end, and give, "at a minimum," the household size and countable income, the enrollee's eligibility category, and enough information to "ascertain the eligibility categories in which the enrollee was tested and the income limits the State applied." The court concluded: "Because Florida's notice system did not provide constitutionally adequate notice, and because the district court properly resolved that claim on a classwide basis and tailored its injunction to that violation, we affirm."

The other side

There was no dissent. As the opinion describes them, Florida argued that Eleventh Circuit precedent in Jordan v. Benefits Review Board (1989) and Arrington v. Helms (2006) does not require a state to disclose individualized findings or calculations, and that the district court erred by requiring "individualized" decisions for each recipient. Florida also argued that other sources of information available to recipients, including DCF's call center and online materials, supplemented the notices, and that the district court went beyond the class claim it had certified. The court acknowledged that "neither case required an agency to reproduce their arithmetic," but held that the notices approved in those cases gave recipients enough information to test the decision against what they already had.

Where it sits in the record

The opinion rests on the Fourteenth Amendment's Due Process Clause and on two Supreme Court decisions, Mullane (1950) and Goldberg v. Kelly (1970), the latter decided on the termination of public assistance benefits. The opinion distinguishes the Eleventh Circuit's own notice decisions in Jordan (black lung benefits) and Arrington (child support payments).