Justia Public Benefits Opinion Summaries

Jaime Norris applied for social security disability benefits and supplemental security income in October 2020, claiming disability due to various mental and physical disorders. The Social Security Administration denied his claim, leading Norris to request a hearing before an administrative law judge (ALJ). During the hearing, both Norris and a vocational expert testified. The ALJ concluded that Norris was not disabled under the Social Security Act, determining that he could adjust to other jobs existing in significant numbers in the national economy. Norris appealed to the Appeals Council, which denied his request for review, finalizing the ALJ's decision.Norris then sought judicial review in the United States District Court for the Northern District of Ohio. The district court affirmed the ALJ's decision, finding that substantial evidence supported the ALJ's conclusion. Norris subsequently appealed to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit reviewed whether the ALJ applied the correct legal standards and whether the findings were supported by substantial evidence. The court affirmed the ALJ's decision, holding that the vocational expert's testimony about the number of jobs available in the national economy constituted substantial evidence. The court rejected Norris's arguments that the ALJ erred in determining the number of significant jobs and that the district court improperly shifted the burden of proof. The court concluded that the ALJ's findings were reasonably drawn from the record and supported by substantial evidence, even if the evidence could support a contrary decision. View "Norris v. Commissioner of Social Security" on Justia Law

Glen Lawson worked for coal-mining companies for twelve years and has a lengthy smoking history, smoking a pack a day for thirty years before quitting in 2014. He is now totally disabled due to respiratory ailments, including chronic obstructive pulmonary disease (COPD), and has used a portable oxygen tank since 2014, required lung surgery in 2017, and been hospitalized with pneumonia several times. In 2017, Lawson applied for benefits under the Black Lung Benefits Act.A claims examiner approved Lawson's application, and an administrative law judge (ALJ) upheld that determination. The Benefits Review Board affirmed the ALJ's decision. Lawson's former employer, Extra Energy, Inc., petitioned the United States Court of Appeals for the Fourth Circuit for review, arguing that Lawson did not provide sufficient evidence that his respiratory disabilities were attributable at least in part to his coal-mining employment rather than solely to his smoking history.The United States Court of Appeals for the Fourth Circuit reviewed the case and denied Extra Energy's petition for review. The court held that the ALJ sufficiently supported his conclusions regarding the cause of Lawson's disabilities. The ALJ credited the opinions of three medical experts who concluded that Lawson's respiratory and pulmonary ailments were caused by both his smoking history and his coal-mine employment, thus diagnosing him with legal pneumoconiosis. The court found that the ALJ's decision was supported by substantial evidence and consistent with applicable law, affirming the award of black-lung benefits to Lawson. View "Extra Energy, Incorporated v. DOWCP" on Justia Law

Karla Smith and Holly Bladel sued Iowa state officials and the State of Iowa after Iowa opted out of federal unemployment programs established during the Covid-19 pandemic. These programs, created under the CARES Act, provided various unemployment benefits. Iowa initially participated in these programs but decided to end its participation in June 2021. Smith and Bladel claimed that this decision violated the U.S. Constitution, the Iowa Constitution, and Iowa state law.The United States District Court for the Southern District of Iowa dismissed the case, ruling that the defendants were immune from suit under the Eleventh Amendment and that the plaintiffs lacked a constitutionally protected property interest in the CARES Act benefits. Smith and Bladel appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The court held that the Eleventh Amendment barred Smith's official-capacity claims against Iowa and its officials, as the claims did not fall under the Ex parte Young exception for ongoing violations of federal law. The court also found that Smith lacked a protected property interest in the CARES Act benefits because Iowa had the discretion to opt out of the programs. Consequently, Smith's due process claim against the Governor and Director in their individual capacities failed. Additionally, the court ruled that Smith's state law claim was barred by the Eleventh Amendment, and her request for declaratory relief was inappropriate as it sought to address past actions rather than future conduct. The court concluded that the district court correctly dismissed all of Smith's claims. View "Smith v. Reynolds" on Justia Law

Dominique Robison, a bus operator for the Washington Metropolitan Area Transit Authority (WMATA), was suspended from her job after bringing her own bottle of urine to a scheduled drug test, which was deemed an automatic failure under WMATA’s policy. She was suspended without pay for 180 days and subsequently filed for unemployment benefits, which were initially granted by the claims examiner due to WMATA's failure to provide evidence of misconduct.WMATA appealed to the Office of Administrative Hearings (OAH), where an administrative law judge (ALJ) found that Robison had committed simple misconduct, not gross misconduct, and was disqualified from benefits for the first eight weeks of her unemployment. The ALJ reasoned that Robison’s violation was her first drug-related offense and that WMATA’s decision to suspend rather than terminate her undercut the severity of the offense. The ALJ did not consider WMATA’s argument that Robison was ineligible for benefits because she was merely suspended, not terminated.WMATA then appealed to the District of Columbia Court of Appeals. The court reviewed whether the ALJ made findings of fact on each materially contested issue, whether substantial evidence supported each finding, and whether the ALJ’s conclusions flowed rationally from its findings. The court concluded that Robison’s actions did not rise to the level of gross misconduct, as there was no direct evidence of drug use or impairment, no demonstrable impact on passenger safety or WMATA’s operations, and it was her first offense. The court also determined that Robison was "unemployed" within the meaning of the statute because she was suspended without pay and did not work during the suspension period.The District of Columbia Court of Appeals affirmed the ALJ’s decision. View "WMATA v. Robison" on Justia Law

Five individuals experienced significant delays in receiving food assistance (SNAP or P-EBT), TANF, or Medicaid benefits. Each requested a hearing before an Administrative Law Judge (ALJ) at the Office of Administrative Hearings (OAH). The ALJs directed the District of Columbia Department of Human Services (DHS) to provide the correct benefits to the claimants, which was eventually done. However, the ALJs also issued orders requiring DHS to correct an "unlawful policy" related to delays caused by internal computer errors or faulty programs.The ALJs' orders were based on the assumption that the delays were due to a systemic issue with DHS's computer systems. DHS representatives mentioned various reasons for the delays, including confusion, human error, and the need for IT tickets to resolve specific issues. In some cases, the delays were attributed to problems with external agencies, such as the Office of the State Superintendent of Education (OSSE). Despite these explanations, the ALJs issued broad orders for DHS to correct its policies.The District of Columbia Court of Appeals reviewed the case and found that the records did not support the conclusion that the delays were due to a DHS policy or systemic computer errors. The court noted that the ALJs did not hold evidentiary hearings or gather substantial evidence to support their findings. The court also found that the ALJs overstepped their authority by issuing broad injunctive relief without a demonstrated need for such measures.The court vacated the challenged orders, concluding that there was no substantial evidence of a DHS policy causing the delays and that the ALJs had not followed proper procedures in issuing their orders. The court emphasized the need for ALJs to base their decisions on substantial evidence and to consider whether broad injunctive relief is necessary. View "District of Columbia Dep't of Human Services v. Butler" on Justia Law

Sean C. Flynn was laid off from his full-time job at Sun Valley Brewing Company during the COVID-19 pandemic and applied for unemployment benefits from the Idaho Department of Labor (IDOL) on March 25, 2020. Flynn received unemployment benefits from March 29, 2020, through June 27, 2020, while he was still employed part-time as a French teacher for the Community School, Inc. Flynn did not report his earnings from the Community School on the weekly certification forms required by IDOL. Additionally, when Flynn returned to full-time work at Sun Valley Brewing, he inaccurately reported his income for the week ending June 27, 2020.Flynn's claim for unemployment benefits was audited two years later, revealing discrepancies in his reported income. IDOL issued an eligibility determination letter retroactively denying Flynn's unemployment benefits and imposing civil penalties for willfully making false statements or failing to report material facts. Flynn appealed to the Idaho Department of Labor Appeals Bureau, arguing that his omissions were honest mistakes. The Appeals Examiner modified IDOL’s determination, finding Flynn misunderstood the reporting requirements for his part-time job but willfully misreported his income from Sun Valley Brewing for one week.IDOL appealed to the Idaho Industrial Commission, which conducted a de novo review and reversed the Appeals Examiner’s decision. The Commission reinstated IDOL’s original eligibility and overpayment determinations, concluding that Flynn’s omissions were willful based on the explicit instructions provided by IDOL and Flynn’s repeated failure to accurately report his income.The Supreme Court of Idaho affirmed the Commission’s decision, holding that Flynn’s omissions constituted a willful misstatement or concealment of material facts under Idaho Code section 72-1366(12). The Court determined that Flynn knew or should have known the necessity of reporting all income, and his failure to do so was intentional. Neither party was awarded attorney fees on appeal. View "Flynn v. Sun Valley Brewing Company" on Justia Law

The City of Huntington and the Cabell County Commission filed lawsuits against AmerisourceBergen Drug Corp., Cardinal Health, Inc., and McKesson Corp., alleging that the defendants contributed to the opioid epidemic by distributing excessive quantities of opioids to pharmacies. The plaintiffs claimed that the defendants' actions created a public nuisance that should be abated under West Virginia common law. The cases were consolidated and remanded to the United States District Court for the Southern District of West Virginia, which held a ten-week bench trial.The district court ruled in favor of the defendants, concluding that the plaintiffs failed to prove that the defendants' conduct was unreasonable or that it proximately caused the opioid epidemic. The court found that the defendants substantially complied with their duties under the Controlled Substances Act (CSA) and that the plaintiffs did not provide sufficient evidence to show that the volume of opioids distributed was excessive or that the defendants failed to maintain effective controls against diversion. The district court also determined that the plaintiffs' proposed abatement plan was not appropriate.The plaintiffs appealed to the United States Court of Appeals for the Fourth Circuit, contesting the district court's factual findings and legal conclusions. The Fourth Circuit certified a question to the Supreme Court of Appeals of West Virginia, asking whether conditions caused by the distribution of a controlled substance can constitute a public nuisance under West Virginia common law and, if so, what the elements of such a claim are.The Supreme Court of Appeals of West Virginia declined to answer the certified question, citing the disputed factual findings and related legal conclusions on appeal. The court emphasized that it could not address the legal issue without a sufficiently precise and undisputed factual record, and any answer would be advisory given the unsettled facts. View "City of Huntington and Cabell County Commission v. AmerisourceBergen Drug Corporation" on Justia Law

Joanne Ecklund received long-term care services through Minnesota’s Medicaid program, the Minnesota Medical Assistance Program (MMAP). The Minnesota Department of Human Services (DHS) paid $66,052.62 in capitated payments to Medica, Ecklund’s managed care organization (MCO), which in turn paid $8,806.84 to care providers for Ecklund’s services. After Ecklund’s death in 2021, DHS sought to recover the $66,052.62 from her estate under Minnesota Statutes section 256B.15, subdivision 2(a)(1), which allows recovery of medical assistance payments for long-term care services provided to recipients aged 55 or older.The district court, adopting a referee’s recommendation, granted summary judgment in favor of the estate’s personal representative, Jerry Ecklund, limiting DHS’s recovery to the $8,806.84 paid by Medica to the care providers. The Minnesota Court of Appeals affirmed, interpreting the statute to limit DHS’s recovery to the amount actually paid to the providers.The Minnesota Supreme Court reviewed the case and reversed the lower courts' decisions. The court held that Minnesota Statutes section 256B.15, subdivision 2(a)(1), allows DHS to recover the amount of capitation payments made to the MCO for long-term care services provided to the recipient. The court reasoned that the statute’s language and the broader statutory context support DHS’s interpretation, which aligns with federal guidance requiring states to recover capitation payments. The court concluded that DHS is entitled to recover the $66,052.62 in capitated payments from Ecklund’s estate. View "In re the Estate of: Ecklund" on Justia Law

Paul Cropper applied for disability insurance benefits and supplemental security income in February 2020, citing various impairments such as anxiety, depression, ADHD, insomnia, and COPD. His application was denied initially and upon reconsideration by the Social Security Administration. Cropper then requested a hearing before an administrative law judge (ALJ), where he presented opinions from his medical providers indicating severe limitations. The ALJ conducted a five-step analysis and denied the application, finding that while Cropper had severe impairments, he could still perform certain jobs available in the national economy. The ALJ found the opinions of Cropper’s primary care provider and psychiatrist unpersuasive.Cropper sought judicial review in the United States District Court for the District of Minnesota, arguing that the ALJ improperly evaluated the evidence, leading to an incorrect residual functional capacity determination. The district court granted summary judgment in favor of the Commissioner, concluding that substantial evidence supported the ALJ’s decision to find the medical opinions unpersuasive.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that the ALJ adequately considered the supportability and consistency of the medical opinions as required by the revised regulations. The court emphasized that the ALJ’s findings were supported by substantial evidence, including the conservative course of treatment and the lack of significant outpatient therapy. The court also noted that the ALJ’s reasoning was sufficiently clear to allow for appropriate judicial review. View "Cropper v. Dudek" on Justia Law

Debra Tucker applied for disability insurance benefits under Title II of the Social Security Act in 2018. After multiple denials at the administrative level, she appealed to the federal district court. In 2023, the district court reversed the final administrative decision of the Commissioner of Social Security, remanding Tucker’s claim for further administrative proceedings. The district court awarded Tucker’s attorney $7,500 in attorney’s fees under the Equal Access to Justice Act (EAJA), along with $402 in costs. Tucker’s attorney had a contingency-fee agreement for twenty-five percent of any past-due benefits awarded. In August 2024, an administrative law judge found Tucker disabled and granted her monthly disability benefits retroactive to February 2018, totaling $124,821.70 in past-due benefits.The district court granted in part and denied in part the attorney’s motion for $31,205.43 in fees under 42 U.S.C. § 406(b), awarding $17,400 instead. The court found the requested fee excessive, amounting to a windfall, and set an imputed hourly rate of $500. The attorney’s motion for reconsideration, reducing the fee request to $22,620, was denied. The attorney appealed, seeking the full $31,205.43.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court found that the district court properly started with the contingency-fee agreement and then tested it for reasonableness, considering the effective hourly rate and other factors. The district court did not misapply the law by comparing the effective hourly rate to the EAJA rate and the attorney’s ordinary rate. The appellate court affirmed the district court’s decision, concluding that it acted within its discretion in reducing the fee to avoid a windfall. View "Tucker v. Commissioner of Social Security" on Justia Law