# Heckler v. Community Health Services of Crawford County, Inc.

> Supreme Court of the United States · May 21, 1984 · 467 U.S. 51

URL: https://www.frixlaw.com/law-library/cases/9429618

## Case

- **Full name:** HECKLER, SECRETARY OF HEALTH AND HUMAN SERVICES v. COMMUNITY HEALTH SERVICES OF CRAWFORD COUNTY, INC., Et Al.
- **Court:** Supreme Court of the United States
- **Decided:** May 21, 1984
- **Citations:** 467 U.S. 51; 52 U.S.L.W. 4621; 104 S. Ct. 2218; 81 L. Ed. 2d 42; 1984 U.S. LEXIS 87
- **Precedential status:** Published
- **Opinion:** Concurrence by Rehnquist
- **Judges:** Stevens, Rehnquist
- **Cited by:** 1,382 later opinions in the Frix Law Library

## Citator (automated)

- **Yellow flag:** Disagreed with by Samuel C. Balderman, M.D. v. United States Veterans Administration and Veterans Administration Medical Center, 870 F.2d 57 (1989).
- Negative treatments: 1
- Distinguished by: 0
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9429618

## How later opinions describe it (automated extraction)

- finding that the government was not bound by representations made by a Medicare fiscal intermediary, and stating that “[t]he relevant statute, regulations, and Reimbursement Manual” made it “perfectly clear” that the intermediary is a conduit and does not make policy decisions
- holding, where the respondent’s “detriment [was] the inability to retain money that it should never have received in the first place,” the “respondent, lost no Nghts but merely was induced to do something which could be corrected at , a later time”
- concluding that public interest would not be harmed by estoppel where government misled plaintiff leading to serious injustice
- stating that, “however heavy the burden might be when an estoppel is asserted against the Government, the private party surely cannot prevail without at least demonstrating that the traditional elements of an estoppel are present”
- recognizing that some of its precedents “seem to rest on the premise that when the Government acts in misleading ways, it may not enforce the law if to do so would harm a private party as a result of governmental deception”

## Opinion text

Justice Rehnquist,
with whom The Chief Justice joins,
concurring in the judgment.
I entirely agree with the Court that there was no estoppel in favor of respondent by reason of the Government’s conduct in this case, because even a private party under like circumstances would not have been estopped. I write separately because I think the Court’s treatment of our decided cases in this area gives an inaccurate and misleading impression of what those cases have had to say as to the circumstances, if any, under which the Government may be estopped to enforce the laws.
Sixty-seven years ago, in Utah Power & Light Co. v. United States, 243 U. S. 389 (1917), private parties argued that they had acquired rights in federal lands, contrary to the law, because Government employees had acquiesced in their exercise of those rights. In that case the Court laid down the general principle governing claims of estoppel on behalf of private individuals against the Government:
*67 “As a general rule, laches or neglect of duty on the part of officers of the Government is no defense to a suit by it to enforce a public right or protect a public interest. [Citations omitted.] And, if it be assumed that the rule is subject to exceptions, we find nothing in the cases in hand which fairly can be said to take them out of it as heretofore understood and applied in this court. A suit by the United States to enforce and maintain its policy respecting lands which it holds in trust for all the people stands upon a different plane in this and some other respects from the ordinary private suit to regain the title to real property or to remove a cloud from it. [Citation omitted.]” Id., at 409 .
Since then we have applied that principle in a case where a private party relied on the misrepresentation of a Government agency as to the coverage of a crop insurance policy, a misrepresentation which the Court agreed would have es-topped a private insurance carrier. Federal Crop Insurance Corp. v. Merrill, 332 U. S. 380, 383-386 (1947). We have applied it in a case where a private party relied on a misrepresentation by a Government employee as to Social Security eligibility, a misrepresentation which resulted in the applicant’s losing 12 months of Social Security benefits. Schweiker v. Hansen, 450 U. S. 785 (1981) (per curiam). And we have applied it on at least three occasions to claims of estop-pel in connection with the enforcement of the immigration laws and the denial of citizenship because of the conduct of immigration officials. INS v. Miranda, 459 U. S. 14 (1982) (per curiam); INS v. Hibi, 414 U. S. 5 (1973) (per curiam); Montana v. Kennedy, 366 U. S. 308, 314-315 (1961). In none of these cases have we ever held the Government to be estopped by the representations or conduct of its agents. In INS v. Hibi, supra, at 8 , we noted that it is still an open question whether, in some future case, “affirmative misconduct” on the part of the Government might be grounds for an estoppel. See Montana v. Kennedy, supra, at 314-315 .
*68 I agree with the Court that there is no need to decide in this case whether there are circumstances under which the Government may be estopped, but I think that the Court’s treatment of that question, ante, at 60-61, gives an impression of hospitality towards claims of estoppel against the Government which our decided cases simply do not warrant. In footnote 12, ante, at 60, the Court intimates that two of our decisions have allowed the Government to be estopped: United States v. Pennsylvania Industrial Chemical Corp., 411 U. S. 655 (1973), and Moser v. United States, 341 U. S. 41 (1951). But these cases are not traditional equitable es-toppel cases. Pennsylvania Industrial Chemical Corp. was a criminal prosecution, and we held that “to the extent that [Government regulations] deprived [the defendant] of fair warning as to what conduct the Government intended to make criminal, we think there can be no doubt that traditional notions of fairness inherent in our system of criminal justice prevent the Government from proceeding with the prosecution.” 411 U. S., at 674 . And the Court’s rather cryptic opinion in Moser , holding that an alien who declined to serve in the Armed Forces was not barred from United States citizenship pursuant to a federal statute, expressly rejected any doctrine of estoppel, and rested on the absence of a knowing and intentional waiver of the right to citizenship. 341 U. S., at 47 .
We do not write on a clean slate in this field, and our cases have left open the possibility of estoppel against the Government only in a rather narrow possible range of circumstances. Because I think the Court’s opinion, in its efforts to phrase new statements of the circumstances under which the Government may be estopped, casts doubt on these decided cases, I concur only in the judgment.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9429618. Public record. Not legal advice.