A decision of a Connecticut appellate court, Bloomfield Health Care Center of Connecticut v. Jason Doyon (Conn. App. Ct., No. AC 40281, Oct. 9, 2018) should serve as a cautionary tale for guardians. In that case, a nursing home brought suit, outside of the guardianship court, against a guardian for failure to timely file a Medicaid application. The lower court dismissed the action for lack of privity but the appellate court reversed and remanded.


Samuel Johnson was admitted to the Bloomfield Nursing Home in April 2013. In September of that year his daughter filed a Medicaid application on his behalf. Medicaid denied that application in January 2014 for failure to provide information, such as an explanation of the proceeds of the sale of Johnson’s home.

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