The Ohio Court of Appeals recently upheld a lower court's decision to dismiss a case involving Mohammed A. Hasan against the Franklin County Medicaid Department and United Healthcare Community Plan. The court ruled on May 12, 2026, that Hasan failed to provide sufficient evidence to support his claims. This ruling has implications for individuals navigating Medicaid and healthcare access in Ohio.

In his complaint, Hasan alleged that the Medicaid department and its partners violated his rights by imposing unwanted healthcare provisions and monitoring his communications. He sought various forms of relief, including access to medical services and the deletion of his medical records. The court's decision highlights the challenges that individuals may face when contesting Medicaid policies and practices.

Background

Mohammed A. Hasan filed his complaint on February 28, 2025, in the Franklin County Court of Common Pleas. Hasan, who holds a Medicaid card, claimed that he suffers from multiple health issues requiring treatment. He accused the Franklin County Medicaid Department, United Healthcare, and the Ohio Department of Medicaid of monitoring his phone calls and internet usage and attempting to force him to live in subpar housing conditions.

Hasan's complaint alleged that these entities violated Section 21(A) of the Ohio Constitution by coercing him into a healthcare system that he did not wish to join. He described the Medicaid plan as inadequate, claiming it denied him access to necessary medical treatments and specialists. Hasan's demands included assurances against interference in his medical affairs, transportation for medical appointments, and reimbursement for past medical expenses.

After filing his complaint, United Healthcare and the Franklin County Medicaid Department responded with motions to dismiss, arguing that Hasan had not stated a valid claim. The trial court agreed, leading to the appeal in the Ohio Court of Appeals. The case was assigned docket number 25AP-763.

The Ruling

The Ohio Court of Appeals, led by Judge Mentel, affirmed the lower court's decision to dismiss Hasan's case. The court found that Hasan's complaint primarily cited a violation of Article I, Section 21(A) of the Ohio Constitution, which prohibits coercion into healthcare systems. However, the court noted that Hasan did not provide sufficient facts to support his claims.

The court stated, "Even accepting all the allegations as true, Hasan has failed to state a claim upon which relief can be granted." This conclusion was based on the lack of evidence that Hasan was compelled, either directly or indirectly, to participate in Medicaid.

The court emphasized that Hasan did not demonstrate any penalties or fines that would indicate he was coerced into the healthcare system. The ruling pointed out that his enrollment in Medicaid appeared to be voluntary, undermining his claims.

As a result, the court found no error in the lower court's dismissal of Hasan's complaint under Civil Rule 12(B)(6), which allows for dismissal when a complaint fails to state a claim upon which relief can be granted.

Impact

This ruling has significant implications for individuals dealing with Medicaid and similar healthcare systems. It reinforces the idea that plaintiffs must provide clear evidence of coercion or violations of constitutional rights when challenging governmental or institutional actions related to healthcare.

The court's decision may deter others from filing similar complaints without substantial evidence, as it sets a precedent for the necessity of demonstrating clear violations of rights. Individuals who feel wronged by Medicaid or other healthcare providers must now be more prepared to substantiate their claims with concrete evidence to avoid dismissal.

Moreover, the ruling could influence how Medicaid departments across Ohio and potentially other states handle complaints and disputes. It emphasizes the need for clear communication and documentation regarding individuals' rights and the obligations of Medicaid providers.

What's Next

Hasan has the option to appeal this ruling to the Ohio Supreme Court, although details were not available in the court filing regarding whether he intends to do so. There are no known related cases pending that would directly affect this ruling.