7th Cir.

SALVATORE ARCIDIACONO v. ELIZABETH M. WHITEHORN and DULCE QUINTERO

June 8, 2026 ·24-3019 ·Panel Decision ·SYKES · By Aisha Johnson

The Seventh Circuit affirmed the dismissal of a class action lawsuit brought by Medicaid beneficiaries. The court found that the plaintiffs lacked standing to sue for injunctive relief due to the absence of a real and immediate threat of future injury.

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Background

The plaintiffs, four Illinois Medicaid beneficiaries, claimed their admission packets to long-term care facilities were mishandled, leading to bills for unreimbursed care. They sought injunctive relief against state officials for systemic reform.

The court’s reasoning

The court concluded that the plaintiffs did not face a real and immediate threat of future injury, as they had not alleged any facts showing a likelihood of future harm stemming from the rejection of their admission packets.

The rejection of their admission packets did not harm them, and they have not alleged any facts showing that they face a real and imminent threat of future injury.

Murthy v. Missouri, 603 U.S. 43, 58 (2024)

What it means going forward

The ruling reinforces the requirement for plaintiffs to demonstrate standing based on a concrete threat of future injury when seeking injunctive relief.