Chianne D. v. Secretary, Florida Agency for Health Care Administ
CourtCourt of Appeals for the Eleventh Circuit
Date FiledNovember 4, 2026
Docket26-10419
StatusPublished
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Full Opinion
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FOR PUBLICATION
In the
United States Court of Appeals
For the Eleventh Circuit
____________________
No. 26-10419
____________________
CHIANNE D. et al.,
Plaintiffs-Appellees,
versus
SECRETARY, FLORIDA AGENCY FOR HEALTH CARE
ADMINISTRATION et al.,
Defendants-Appellants.
____________________
Appeal from the United States District Court
for the Middle District of Florida
D.C. Docket No. 3:23-cv-00985-MMH
____________________
Before JORDAN, ROSENBAUM, and LAGOA, Circuit Judges.
LAGOA, Circuit Judge:
Florida provides Medicaid coverage to qualifying low-in-
come residents. When the Florida Department of Children and
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2 Opinion of the Court 26-10419
Families (“DCF”) determines that an enrollee is no longer finan-
cially eligible, it sends the enrollee a written Notice of Case Action
stating that his Medicaid benefits will end.
Plaintiffs here are Medicaid enrollees who received notices
after the State determined that their household income was too
high to qualify. On behalf of a certified class, they challenged the
notices under the Due Process Clause, arguing that the notices
failed to adequately communicate Florida’s termination decision
and the reasons behind it. After a bench trial, the district court
agreed and entered a declaratory judgment in favor of Plaintiffs,
along with a permanent injunction requiring Florida to provide
that information before terminating a class member’s Medicaid
benefits. After careful review, and with the benefit of oral argu-
ment, we affirm.
I. BACKGROUND1
A. Florida’s Medicaid Eligibility Process
Florida participates in Medicaid. The Florida Agency for
Health Care Administration (“AHCA”) is the State’s Medicaid
payor, while DCF determines Medicaid eligibility. Fla. Stat.
§ 409.902(1). During the COVID-19 pandemic, federal law re-
quired participating States receiving enhanced Medicaid funding to
suspend eligibility reviews and maintain most existing Medicaid en-
rollment. Congress ended that requirement on March 31, 2023,
1 The following facts are drawn from the evidence and testimony admitted at
the July and August 2024 bench trial.
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26-10419 Opinion of the Court 3
and Florida resumed regular eligibility reviews in what became
known as the Medicaid “unwinding.” Between April 2023 and
March 2024, DCF redetermined the eligibility of more than four
million people.
This case concerns the Family-Related Medicaid program,
which covers groups including parents and caretakers, pregnant
women, infants, and children. For those groups, DCF first deter-
mines whether a person satisfies the program’s nonfinancial re-
quirements and then determines financial eligibility. Financial eli-
gibility generally turns on modified adjusted gross income. See 42
U.S.C. § 1396a(e)(14)(A); 42 C.F.R. § 435.603(c)–(f ). DCF deter-
mines whose income counts through what it calls a Standard Filing
Unit (“SFU”) and compares the resulting income calculation
against an income limit that varies with the person’s eligibility cat-
egory and SFU size.
A person who satisfies the nonfinancial requirements for
Family-Related Medicaid but exceeds the applicable income limit
may instead qualify for the Medically Needy Program. Unlike full
Medicaid, Medically Needy coverage generally begins only after
the recipient incurs a specified “share of cost” during each month.
DCF uses a mainframe computer system called FLORIDA
to make these eligibility determinations. If the FLORIDA system
determines a recipient is ineligible to receive Medicaid, DCF gen-
erates a written notice. The notice is the only written communica-
tion DCF affirmatively sends to a recipient to explain its final eligi-
bility decision.
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4 Opinion of the Court 26-10419
A single notice may contain decisions concerning several
public benefit programs, household members, and time periods. It
may also contain multiple sections with the same “Medicaid” or
“Medically Needy” heading. Although those sections can reflect
different Medicaid eligibility categories, the notices generally do
not identify which category a particular section addresses.
For an income-based Medicaid termination, the notice con-
tains a section stating that Medicaid benefits for the listed person
or persons will end on a specified date. Other portions of the no-
tice may state that household income exceeds Medicaid’s limit or
otherwise provide a standardized “Designated Reason” generated
from one of DCF’s reason codes. Some income-based termination
notices, however, did not contain a Designated Reason identifying
income as the basis for DCF’s decision.
The challenged notices here also did not state the SFU size,
countable income, or income limit DCF used in making the deter-
mination. Nor did they identify the Medicaid eligibility category
under which DCF evaluated the recipient or the other categories
DCF considered.
After receiving a notice, recipients can seek more infor-
mation from several sources about their benefits or a termination
decision. DCF operates a call center whose agents can consult
FLORIDA, case notes, applications, third-party income records,
and policy materials. DCF also maintains Family Resource Cen-
ters, the MyACCESS online portal, and public Medicaid materials.
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26-10419 Opinion of the Court 5
And a recipient can request a hearing to contest a termination de-
cision. See Fla. Admin. Code rr. 65-2.044, 65-2.045. After a hearing
request, DCF generally conducts a supervisory review in which a
supervisor can examine the underlying eligibility determination,
explain it to the recipient, and correct any error before the hearing.
B. The Challenged Notices
The named plaintiffs all received income-based termination
notices during the Medicaid “unwinding.” Their notices were dif-
ferent in length and in the number and order of Medicaid and Med-
ically Needy sections, but each illustrates the problems with the
notices at issue in this case.
For example, DCF sent Chianne D. an eleven-page notice
containing eight separate health-benefit sections. One Medicaid
section listed every household member, including her newborn son
S.D., as ineligible. The notice stated that the listed recipients were
ineligible because “your household’s income is too high,” but it did
not disclose the SFU, income figure, or income level used in deter-
mining eligibility. Several pages later, however, another section
stated that S.D. remained eligible for Medicaid as a newborn. That
latter section reflected DCF’s actual decision; S.D.’s coverage never
ended. Chianne D.’s own coverage, however, was terminated after
DCF incorrectly ended her continuous postpartum coverage and
evaluated her under a different eligibility category. DCF later re-
stored her Medicaid retroactively.
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6 Opinion of the Court 26-10419
Kimber Taylor and her newborn son K.H. received a nine-
page notice stating that their Medicaid would end but that her new-
born was eligible for the Medically Needy program. The notice did
not disclose the SFU, income figure, or income level that DCF had
used to determine Taylor and her newborn’s ineligibility for full
Medicaid. DCF later determined that both terminations were er-
roneous: Taylor remained entitled to continuous postpartum cov-
erage, and K.H. remained entitled to continuous coverage as an in-
fant born to a mother receiving Medicaid. DCF restored their cov-
erage retroactively.
A.V.’s eight-page notice contained seven Medically Needy
sections before the Medicaid termination section. The notice did
not disclose the SFU, income figure, or income limit DCF had used
in determining A.V.’s eligibility. The record shows that DCF used
an SFU of six instead of eight, which reduced the applicable
monthly income limit from $6,110 to $4,868, and also attributed
$6,456.99 in monthly income to the family even though the family
had reported $4,727.10. DCF later corrected the calculation and
restored A.V.’s Medicaid.
C. Proceedings Below
Plaintiffs brought this action against the Secretaries of
AHCA and DCF, alleging that Florida’s Medicaid termination no-
tices violated the Due Process Clause and the Medicaid Act. They
sought declaratory and injunctive relief. The district court certified
the following class, pursuant to Federal Rule of Civil Procedure
Rule 23(b)(2):
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26-10419 Opinion of the Court 7
All Florida Medicaid enrollees who on or after March
31, 2023, have been or will be found ineligible for
Medicaid coverage based on a finding that the individ-
ual or household has income that exceeds the thresh-
old for Medicaid eligibility, and were issued a written
notice that does not identify the individualized in-
come used in the eligibility determination or the in-
come standard applied.
The district court also certified a subclass consisting of class mem-
bers “whose written notice does not provide a Designated Reason
or includes only Designated Reasons that do not identify income as
the factor on which the State relied in finding the individual to be
ineligible for Medicaid.”
After a six-day bench trial, Plaintiffs dismissed their Medicaid
Act claim, leaving only the due-process claim. The district court
later entered findings of fact and conclusions of law in Plaintiffs’
favor.
The district court first addressed the notices themselves. It
found that they did not “unambiguously communicate the State’s
decision to terminate benefits, the reason for that decision, or to
whom it applies.” As the district court found, the notices were “ex-
ceedingly confusing and contradictory in their language and con-
struction.” Further, the district court found that the notices did not
provide enough case-specific information for recipients to under-
stand how DCF had reached a termination decision, making it “dif-
ficult, if not impossible, for the recipient to understand the State’s
intended action as to each enrollee or the reasons for that action.”
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8 Opinion of the Court 26-10419
The district court then considered whether Florida’s other
sources of information cured those problems. It found that they
did not. It determined that the call center did not provide accurate
explanations of eligibility decisions. Further, MyACCESS and
DCF’s public materials did not provide the missing case-specific in-
formation. And although employees at Family Resource Centers
could access case information, DCF did not direct recipients there
to help them understand a termination decision.
DCF’s supervisory review process offered a fuller explana-
tion for those seeking clarity for a termination decision. But that
review began only after a recipient requested a hearing. The dis-
trict court found that this review process “comes too late in the
process to provide the enrollee with the information she needs to
decide whether to appeal” the termination decision in the first
place. (emphasis omitted). Based on these findings, the district
court concluded that Florida’s methods of notice were insufficient
“to meet the requirements of due process under the circum-
stances.”
The district court entered a permanent injunction barring
Florida from terminating a class member’s Medicaid for financial
ineligibility unless the written notice (i) unambiguously states that
Medicaid coverage will end; (ii) identifies each person whose cov-
erage will end; and (iii) explains the reason for the decision as to
that person. For an income-based termination, the order requires
the notice to include, “at a minimum,” the enrollee’s “household
size (SFU) and countable income” as determined by the State, to
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26-10419 Opinion of the Court 9
identify “the eligibility category in which the enrollee had been re-
ceiving benefits” and explain any change, and to provide enough
information for the recipient to “ascertain the eligibility categories
in which the enrollee was tested and the income limits the State
applied.”
Florida timely appealed.
II. STANDARD OF REVIEW
“After a bench trial, we review the district court’s conclu-
sions of law de novo and the district court’s factual findings for
clear error.” Proudfoot Consulting Co. v. Gordon, 576 F.3d 1223, 1230
(11th Cir. 2009) (citing Renteria–Marin v. Ag–Mart Produce, Inc., 537
F.3d 1321, 1324 (11th Cir. 2008)).
III. ANALYSIS
Florida raises several arguments on appeal, but they reduce
to two central issues. The first is whether Florida’s income-based
Medicaid termination notices, considered together with the other
sources of information available to recipients, satisfy due process.
The second is whether the district court violated Rule 23 by resolv-
ing the adequacy of those notices on a classwide basis and entering
the resulting injunction. We address each in turn.
A. Whether Florida’s Notice System Satisfies Due Process
1. Governing Principles
The Due Process Clause provides that no State shall “deprive
any person of life, liberty, or property, without due process of law.”
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U.S. Const. amend. XIV, § 1. When the government proposes to
deprive someone of a protected interest, the Supreme Court has
explained that 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.”
Mullane v. Cent. Hanover Bank & Tr. Co., 339 U.S. 306, 314 (1950) (ci-
tations omitted). 2 Further, a notice “must be of such nature as rea-
sonably to convey the required information, and it must afford a rea-
sonable time for those interested to make their appearance.” Id.
(emphasis added) (citations omitted).
The Supreme Court has clarified that, in the context of ter-
mination of public benefits, due process requires that a recipient
must “have timely and adequate notice detailing the reasons for a
proposed termination, and an effective opportunity to defend by
confronting any adverse witnesses and by presenting his own argu-
ments and evidence orally.” Goldberg v. Kelly, 397 U.S. 254, 267–68
(1970) (emphasis added). Those explanations matter where a recip-
ient wants to challenge termination decisions “as resting on incor-
rect or misleading factual premises or on misapplication of rules or
policies to the facts of particular cases.” Id. at 268.
Taken together, Mullane and Goldberg frame the question the
district court confronted: considering “all the circumstances,” were
2 We have repeatedly confirmed that Mullane, not the later three-factor bal-
ancing test of Mathews v. Eldridge, 424 U.S. 319 (1976), governs the adequacy
of notice. See Grayden v. Rhodes, 345 F.3d 1225, 1242 (11th Cir. 2003); Arrington
v. Helms, 438 F.3d 1336, 1349 (11th Cir. 2006).
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26-10419 Opinion of the Court 11
Florida’s notices and the other means available to recipients “rea-
sonably calculated” to provide “timely and adequate notice detail-
ing the reasons” DCF was terminating their Medicaid benefits?
Mullane, 339 U.S. at 314–15; Goldberg, 397 U.S. at 267–68. After a six-
day bench trial, the district court found that the notices did not “un-
ambiguously communicate the State’s decision to terminate bene-
fits, the reason for that decision, or to whom it applies,” and that
the other available sources did not cure those deficiencies. We
agree.
2. The Notices of Case Action
The deficiency is apparent from Chianne D.’s notice. Her
April 24, 2023, notice spans eleven pages and contains eight sepa-
rate sections concerning health benefits. The first Medicaid section
lists every member of the household, including her newborn son
S.D., as ineligible for Medicaid because the “income is too high.”
Several pages later, another section contradicts the earlier state-
ment and states S.D. is eligible for Medicaid as a newborn. That
second statement reflected DCF’s actual decision; S.D.’s Medicaid
was never terminated. But nothing in the notice explained the con-
flicting information.
When Chianne D. called DCF for help, a Tier 3 agent read
the same notice and told her that S.D.’s Medicaid was ending be-
cause the household’s income was too high. The district court
found that the agent “misunderstood the notice due to its multiple
sections and gave Chianne D. the wrong answer,” even though the
agent had earlier recognized that S.D.’s Medicaid remained open.
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When a trained DCF employee could read the notice and come
away with the wrong answer about whose coverage was ending,
the district court did not err in finding that the notice did not rea-
sonably convey DCF’s decision to its intended recipient.
Even when a recipient located the termination section and
understood that income was involved, another problem remained.
A notice stating “your household income is too high” gives the re-
cipient DCF’s conclusion. But financial eligibility for Medicaid
turns on several factors including: (1) the countable income that
DCF attributes to the recipient’s SFU; (2) the size of that SFU; (3)
the eligibility category under which DCF evaluated the recipient;
and (4) the income limit corresponding to that category and SFU.
The challenged notices did not disclose enough of those inputs for
recipients to check DCF’s determination against their own records.
Thus, for A.V.’s eligibility determination, DCF used an SFU
of six when the correct SFU was eight. That mistake caused DCF
to apply an income limit of $4,868 instead of $6,110. DCF also
calculated the family’s earned income as $6,456.99, even though
the family had reported $4,727.10. Yet A.V.’s notice did not tell her
mother the SFU or income standard DCF had used. William Rob-
erts, who works in DCF’s Medicaid Policy Unit and who testified
at the bench trial, could not determine why A.V. had been found
financially ineligible by looking at the notice, the family’s MyAC-
CESS account, or DCF’s website. Roberts needed DCF’s internal
Budget screen, which Medicaid recipients cannot access. Thus, the
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26-10419 Opinion of the Court 13
information needed to understand what DCF had done was availa-
ble inside the agency but not to the person whose coverage DCF
terminated.
These gaps in crucial information are precisely the concern
that Goldberg addresses. When an agency’s decision may rest on an
“incorrect or misleading factual premise[]” or a mistaken applica-
tion of its rules to a particular person, due process requires notice
“detailing the reasons” for the termination. 397 U.S. at 267–68. A
recipient who is informed only that his “income is too high” cannot
tell whether DCF has based its determination on the wrong in-
come, counted the wrong people in the recipient’s SFU, evaluated
the recipient under the wrong Medicaid category, or applied the
wrong income limit. And without knowing which premise DCF
used, the recipient does not know what objection to make.
Florida argues that our decisions in Jordan v. Benefits Review
Board, 876 F.2d 1455 (11th Cir. 1989), and Arrington v. Helms, 438 F.3d
1336 (11th Cir. 2006), do not require the State to disclose individu-
alized findings or calculations, and that the district court erred by
requiring “individualized” termination decisions as to each recipi-
ent. True, neither case required an agency to reproduce their arith-
metic. But the notices we approved in those cases at least gave their
recipients something Florida’s notices clearly do not: enough con-
crete information to understand the basis of the decision and to
test it against information already available to them.
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In Jordan, the agency denied black lung benefits because the
claimant there had failed to meet one of three eligibility require-
ments. The termination notice listed all three requirements and
identified the one the claimant had failed to prove. 876 F.2d at
1458–59. The notice also defined the relevant requirement and re-
ferred the claimant to a guide explaining the evidence that could
satisfy it. Id. Under those circumstances, we held that the notice
provided “sufficient detail to pass the notice requirement of due
process.” Id. at 1459. The claimant in Jordan did not receive every
step of the agency’s reasoning, but he knew what part of his claim
had failed and what evidence was relevant.
The notice in Arrington provided recipients a similar ability
to check the government’s work. Alabama’s monthly child support
notice identified the relevant court order and gave the amounts
paid toward current support, arrears, and the family. 438 F.3d at
1350. A parent could compare the amount shown in the notice
with the parent’s child support order, then compare the amount
Alabama said it paid to the family with the parent’s payment check
stub. Id. If questions remained after that comparison, the check
stub directed the parent to a 24-hour hotline, and customer-service
representatives were available by telephone, fax, mail, email, or in
person. Id. at 1350–51. The notice and those additional resources
together gave parents “ample information with which to deter-
mine” whether they had received the correct payment. Id.
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Florida’s notices provide no comparable starting point.
They do not identify the individualized income used or the appli-
cable standard against which DCF measured it. Unlike the recipi-
ents in Jordan and Arrington, then, a class member cannot use the
notice and information already in their possession to identify the
disputed premise or check the agency’s work.
Based on the evidence before it, the district court did not err
in concluding that Florida’s notices fail to meet due process require-
ments because they are too vague and confusing to reasonably in-
form recipients what action the State intends to take, to whom that
action applies, or why the State is taking it.
3. Other sources of information
But that deficiency alone does not end our inquiry. Due pro-
cess asks whether Florida’s notice system, considered as a whole,
was “reasonably calculated, under all the circumstances,” to convey
the information recipients needed to understand and challenge the
termination. Mullane, 339 U.S. at 314; Jordan, 876 F.2d at 1459. We
therefore turn to the other sources of information that Florida says
supplement its otherwise deficient written notices.
The record gave the district court good reason to find those
sources unreliable for that purpose. Start with the call center. In
April 2024, DCF blocked 744,000 calls before they could enter a
queue for a live agent, representing 53.9 percent of the calls re-
questing an agent. Of the calls that entered a queue, another 31.3
percent ended before an agent answered. Those figures count calls
rather than unique recipients and therefore do not establish how
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16 Opinion of the Court 26-10419
many individual Medicaid recipients ultimately failed to reach DCF.
But they support the district court’s finding that the call center re-
ceived “far more calls with requests for live agents than it is
equipped to handle.”
Reaching an agent did not necessarily answer the question
for several class members who tried to ascertain the reason for the
termination of their benefits. When the FLORIDA system moves
a recipient from “Medicaid” to “Medically Needy,” it deletes the
Budget screen containing the Medicaid termination determination.
An agent who attempts to explain the basis for a termination may
therefore have to reconstruct that determination from scratch us-
ing information elsewhere in DCF’s system. This often resulted in
long delays and incorrect information being provided to recipients
who did reach an agent.
Florida’s reliance on the call center assumes that a recipient
who cannot understand the notice can simply ask DCF what the
agency actually decided. But there is a fundamental problem that
goes unaddressed by Florida: what is the recipient to do when
DCF’s answer conflicts with the notice? That happened here. One
agent told Chianne D. that she and C.D. were “good” and remained
covered through May 2024, when DCF was in fact terminating her
full Medicaid coverage. A Tier 3 agent later read the notice and
incorrectly told Chianne D. that S.D.’s Medicaid was ending be-
cause the household’s income was too high, even though another
section of the same notice said that S.D. remained eligible.
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Faced with competing answers from the agency itself, a re-
cipient has no reliable basis for knowing which one to trust. Re-
quiring a recipient to independently determine which account is
correct brings us back to the task that the notices are supposed to
perform in the first place.
The problem is compounded because a recipient must then
decide whether to request a hearing and challenge the termination
decision. If the recipient relies on the agent and the agent is wrong,
the recipient may forgo a hearing that the recipient needed. If in-
stead the recipient relies on a confusing or contradictory notice, the
recipient still may not know what factual premise or eligibility de-
termination to contest. Either way, Florida has not given the recip-
ient a reliable basis for making the choice Mullane says belongs to
the recipient: whether to “acquiesce or contest.” 339 U.S. at 314.
The remaining sources of information did not fill the gap
left behind by the inadequate notices. For example, MyACCESS
did not provide the case-specific information that was omitted
from the notices. DCF’s Policy Manual and Appendix A-7 describe
Medicaid rules generally, but they do not tell a recipient what in-
come, SFU, eligibility category, or income limit DCF actually used
in the recipient’s case. And although employees at Family Resource
Centers could access specific case information, neither the notices
nor DCF’s website told recipients to visit those centers to help un-
derstand a termination decision.
The timing of DCF’s supervisory review also shows why
these gaps in information leave a recipient with little understanding
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18 Opinion of the Court 26-10419
about what is happening and why. Once a recipient requests a hear-
ing, a supervisor independently reviews the eligibility determina-
tion. As part of that process, the supervisor reviews the applica-
tion, the notice, DCF’s Budget and other internal screens, the gov-
erning policies, the income tables, and third-party income records.
The supervisor then contacts the recipient and explains “how the
decision was made, the reason for the decision, and the facts used
to make the decision,” including the income and policies DCF ap-
plied.
That is essentially the explanation the recipient needed be-
fore deciding whether to challenge the termination. But DCF pro-
vides it only after the recipient has requested a hearing. As the dis-
trict court found, “the review occurs only after an individual has
made the decision to appeal. Thus, it comes too late in the process
to provide the enrollee with the information she needs to decide
whether to appeal.” (emphasis omitted).
Mullane speaks directly to Florida’s backwards sequence.
“This right to be heard has little reality or worth unless one is in-
formed that the matter is pending and can choose for himself
whether to appear or default, acquiesce or contest.” 339 U.S. at 314.
Goldberg followed the same logic. There, a caseworker with doubts
about continued eligibility had to “first discuss them with the re-
cipient” before recommending termination. 397 U.S. at 258. If the
caseworker still believed the recipient was ineligible, the agency
sent a letter stating the reasons for the proposed termination and
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26-10419 Opinion of the Court 19
explaining how to seek further review. Id. at 258–59. Before decid-
ing whether to contest the termination, the recipient thus knew
“the precise questions raised about his continued eligibility” and
“the legal and factual bases for the Department’s doubts.” Id. at
268. Florida’s process runs in the opposite direction with the fuller
explanation coming only after the recipient decides to object.
Contrary to Florida’s arguments, the district court did not
impose a rule requiring every agency to reproduce every internal
calculation in every notice. Rather, it applied Mullane and Goldberg
to the notice system proved at trial. Here, DCF’s eligibility deter-
mination turns on the recipient’s SFU and countable income, the
eligibility category DCF used, and the corresponding income limit.
Those were also among the premises on which the record revealed
actual errors. On this record, Florida did not provide that infor-
mation through its notices or through another method reasonably
calculated to convey it before recipients had to decide whether to
object.
We therefore find no error with the district court’s determi-
nation that Florida’s notice system did not satisfy due process.
B. The Classwide Ruling and Injunction
Florida next argues that the district court went beyond the
class claim it certified. According to Florida, the court only certi-
fied a challenge to the information omitted from the notices but
later decided a different “structural claim” about how the notices
communicated the State’s decision. Because that supposed claim
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20 Opinion of the Court 26-10419
was never certified, Florida argues, the district court could not de-
cide it for the class. We disagree.
Rule 23(c)(1)(B) requires a certification order to “define the
class and the class claims, issues, or defenses.” Fed. R. Civ. P.
23(c)(1)(B). The district court did that here. It limited the class to
Medicaid enrollees whom Florida found financially ineligible and
who received a notice that (1) did not identify the income used in
the eligibility determination or (2) the income standard applied. It
also certified a subclass whose notices contained no Designated
Reason or only Designated Reasons that did not identify income as
the basis for the decision.
The certification order also identified what the court would
decide at trial. It described “[t]he central question” as “what infor-
mation and degree of detail must be included in a Medicaid termi-
nation notice to satisfy the Due Process Clause.” And, recognizing
that the notices were not identical, the court said it would “consider
the adequacy of the notice in its entirety and under the totality of
the circumstances.” The question, it explained, was whether Flor-
ida’s notices were “reasonably calculated to apprise intended recip-
ients, as a whole, of their rights.”
The district court’s inquiry thus necessarily included how the
notices communicated the information they contained, not simply
what they said. Mullane requires that a notice “reasonably” convey
the required information. 339 U.S. at 314. So, if multiple sections,
conflicting statements, or the way household members are
grouped together make it unclear what DCF decided or to whom
USCA11 Case: 26-10419 Document: 46-1 Date Filed: 11/04/2026 Page: 21 of 23
26-10419 Opinion of the Court 21
the decision applies, those facts are directly relevant to the due pro-
cess claim certified for classwide consideration. Contrary to Flor-
ida’s argument, they do not create a second constitutional claim
called “structure.”
The class certification order itself anticipated that inquiry,
recognizing that “the content of each termination notice varies.”
Even so, after limiting the class to income-based terminations, the
district court found common omissions across the notices and con-
cluded that they were “sufficiently similar as to allow review of
their adequacy across the class.” Indeed, when Florida argued that
other language in particular notices had to be considered, the court
agreed: the notices would be reviewed “in their entirety.”
In the end, the district court certified a narrow class. It ex-
cluded Medicaid terminations based on reasons other than income
because different reasons might require different explanations. The
class therefore includes only recipients whose Medicaid was termi-
nated because DCF found their income too high and whose notices
omitted either the income DCF used or the income limit. The
common question was whether those notices gave recipients ade-
quate notice of an income-based termination.
That common question does not turn on whether every no-
tice looked the same. Jordan asks whether the notice was “reason-
ab