Justia Public Benefits Opinion Summaries

Several unemployed workers in Alabama applied for unemployment benefits and claimed that the Alabama Department of Labor unlawfully delayed processing their claims. They sued the Alabama Secretary of Labor in state court under 42 U.S.C. §1983, arguing that the delays violated their due process and federal statutory rights. They sought a court order to expedite the processing of their claims. The Secretary moved to dismiss the complaint, arguing that the claimants had not satisfied the administrative-exhaustion requirement under Alabama law. The state trial court granted the motion and dismissed the complaint.The claimants appealed to the Alabama Supreme Court, which affirmed the dismissal on the grounds of failure to exhaust administrative remedies. The court concluded that §1983 did not preempt the state's administrative-exhaustion requirement, effectively preventing the claimants from suing to expedite the administrative process until they had completed it.The Supreme Court of the United States reviewed the case and held that state courts may not deny §1983 claims on failure-to-exhaust grounds when the application of a state exhaustion requirement effectively immunizes state officials from such claims. The Court reasoned that Alabama's exhaustion requirement, as applied, prevented claimants from challenging delays in the administrative process, thus immunizing state officials from §1983 suits. The Court reversed the Alabama Supreme Court's decision and remanded the case for further proceedings consistent with its opinion. View "Williams v. Reed" on Justia Law

Ken Lick Coal Company employed Bob Reed from 1973 to 1986, during which he was exposed to coal dust. Reed later worked for Green Valley Hydro Seeding & Reclamation and JPR, where he continued to be exposed to coal dust. Reed developed breathing problems and filed three claims for black-lung benefits. His first claim in 1986 was denied. His second claim in 2007 was initially granted but later denied by an administrative law judge who found Reed did not have pneumoconiosis. Reed's third claim in 2018 was pursued by his widow after his death.The district director awarded benefits and designated Ken Lick as the responsible operator. An administrative law judge upheld this decision, finding Reed had over 15 years of coal-mine employment, including his work with Green Valley and JPR. The judge also found that Ken Lick had stipulated to being the responsible operator during Reed's second claim, which the judge deemed binding in the third claim.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the administrative law judge erred in treating Ken Lick's prior stipulation as binding. The court found that the stipulation was a legal conclusion rather than a factual one, and thus, the judge had the authority to disregard it. The court noted that the administrative law judge would not have required Ken Lick to pay the benefits but for the stipulation. Consequently, the Sixth Circuit granted Ken Lick's petition for review and transferred the liability for Reed's claim to the Black Lung Disability Trust Fund. View "Ken Lick Coal Co. v. OWCP" on Justia Law

Dale Staten, a coal miner for nearly thirty years, retired in 2000 and passed away in January 2017 from respiratory failure after a two-week hospitalization. His widow, Bernadette Staten, filed for survivor benefits under the Black Lung Benefits Act. A Department of Labor administrative law judge (ALJ) awarded benefits, concluding that Bernadette qualified for a statutory presumption that Dale died from black lung disease due to his extensive underground mining work and total disability at the time of his death. The Benefits Review Board affirmed the ALJ's decision in a divided ruling.Consolidation Coal Company (CONSOL), Dale's former employer, challenged the ALJ's award, arguing that the 15-year presumption should only apply to chronic pulmonary conditions, not acute illnesses like Dale's respiratory failure. CONSOL contended that Dale's total disability was due to an acute condition rather than a chronic one. The ALJ had credited Dr. Sanjay Chavda's opinion that Dale was totally disabled at the time of his death, while discounting the opinions of CONSOL's experts, Dr. James Castle and Dr. Robert Farney, who argued that Dale was not disabled based on his medical history before his hospitalization.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the ALJ's award of benefits. The court held that the Black Lung Benefits Act does not require a claimant to prove that a miner's total disability arose from a chronic pulmonary condition to invoke the 15-year presumption. The court found that the ALJ acted within its authority in crediting Dr. Chavda's opinion and concluding that CONSOL failed to rebut the presumption that Dale's death was due to pneumoconiosis. The court denied CONSOL's petition for review and affirmed the judgment of the Benefits Review Board. View "Consolidation Coal Company v OWCP" on Justia Law

A young adult with intellectual and developmental disabilities, referred to as G.J.F., moved to Alaska in 2021 and was referred by a homeless shelter to Volunteers of America Alaska (VOA), a nonprofit organization. VOA provided intensive case management support, including housing assistance and help with applying for government benefits. Despite initial resistance from G.J.F., a consistent therapeutic relationship was eventually established. VOA petitioned the superior court to appoint the Public Guardian as a full guardian for G.J.F., arguing that less restrictive alternatives were not feasible or adequate to meet G.J.F.'s needs.The superior court appointed a visitor and scheduled a hearing. The visitor's report and a neuropsychological evaluation indicated that G.J.F. had multiple mental health diagnoses and significant difficulties with decision-making and daily living tasks. The master recommended a full guardianship, but the Public Guardian objected, leading to an evidentiary hearing. At the hearing, VOA staff testified about the extensive support they provided to G.J.F. and the limitations of their services. The court found that VOA's services were not sustainable and that G.J.F. needed decision-making support that only a full guardian could provide.The Supreme Court of the State of Alaska reviewed the case and affirmed the superior court's order appointing the Public Guardian as a full guardian for G.J.F. The court held that the superior court did not abuse its discretion in determining that less restrictive alternatives were not feasible or adequate to meet G.J.F.'s needs. The court found that the record contained clear and convincing evidence supporting the need for a full guardianship, given G.J.F.'s significant vulnerabilities and the limitations of VOA's support. The court also noted that relying on the visitor's report, which was not admitted into evidence, was harmless error because the same information was provided through other evidence. View "In the Matter of the Protective Proceedings of G.J.F" on Justia Law

Donald Hunter, a former coal miner, applied for benefits under the Black Lung Benefits Act (BLBA) in 2019, claiming that he was totally disabled due to chronic obstructive pulmonary disease (COPD) caused by his coal mine employment. Southern Ohio Coal Company, his former employer, contested his claim, arguing that Hunter's COPD was caused by his significant history of smoking cigarettes rather than coal mine dust exposure.An Administrative Law Judge (ALJ) reviewed the case and awarded benefits to Hunter, finding that his COPD constituted legal pneumoconiosis and that it was a substantially contributing cause of his total disability. Southern Ohio Coal appealed to the Benefits Review Board (BRB), arguing that the ALJ erred in discrediting its evidence and in crediting Hunter's evidence. The BRB affirmed the ALJ's decision, holding that the ALJ had properly considered and weighed the evidence.The United States Court of Appeals for the Sixth Circuit reviewed the case. Southern Ohio Coal argued that the ALJ erred by relying on a pulmonary function test (PFT) that did not comply with regulatory quality standards and by relieving Hunter of his burden to establish entitlement to benefits. The court found that the ALJ acted within his discretion in determining that the PFT was compliant and supported Hunter's entitlement to benefits. The court also held that the ALJ did not improperly rely on regulatory guidance or flip the burden of proof to Southern Ohio Coal. The ALJ's decision was supported by substantial evidence, including expert opinions and Hunter's testimony.The Sixth Circuit denied the petition for review, affirming the ALJ's decision to award benefits to Hunter. The court held that the ALJ correctly applied the law and that his decision was supported by substantial evidence. View "Southern Ohio Coal Co. v. Office of Workers' Compensation Programs" on Justia Law

Joshua Smitson applied for social security disability benefits and supplemental security income, claiming that his asthma and chronic obstructive pulmonary disease (COPD) prevented him from working. His medical records indicated frequent episodes of shortness of breath and difficulty walking and standing for long periods. He was hospitalized for a week in 2021 due to an acute respiratory exacerbation. Smitson used a nebulizer four times a day, with each session lasting about thirty minutes. Despite his conditions, his medication regimen effectively controlled his symptoms.An administrative law judge (ALJ) denied Smitson's application for benefits, concluding that his conditions were limiting but not disabling. The ALJ found that Smitson could manage his symptoms with proper medical treatment and determined that he had the residual functional capacity (RFC) to perform "light work" with certain limitations. A vocational expert testified that jobs were available for someone with Smitson's RFC. The United States District Court for the Southern District of Indiana affirmed the ALJ's decision. After Smitson's death, his widow, Lacey Thorlton, continued the appeal.The United States Court of Appeals for the Seventh Circuit affirmed the ALJ's decision. The court emphasized that claimants bear the burden of proving their disability and that the ALJ's decision must be supported by substantial evidence. The court found that the ALJ's conclusion that Smitson could perform light work was supported by substantial evidence, including medical records showing that his conditions were well-managed with medication. The court acknowledged that the ALJ could have more directly addressed Smitson's testimony about his nebulizer use but concluded that the ALJ's decision, when viewed holistically, sufficiently considered this evidence. The court found no compelling evidence in the record to reverse the ALJ's decision. View "Thorlton v King" on Justia Law

Edna Napier, a former cashier and certified nursing assistant, applied for disability insurance benefits due to severe physical conditions and mental impairments, including depression and anxiety. Her initial application was denied by the Social Security Administration (SSA) in 2018. Napier filed a new application in December 2019, claiming she had been unable to work since December 2018. An administrative law judge (ALJ) held an evidentiary hearing and concluded that Napier was not disabled under the Social Security Act, finding that her mental impairments were mild and her physical impairments did not prevent her from performing her past work as a cashier.The United States District Court for the Eastern District of Kentucky affirmed the ALJ's decision. Napier appealed, arguing that the ALJ erred in assessing the severity of her mental impairments and failed to account for them in her residual functional capacity (RFC) analysis.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the ALJ's decision was supported by substantial evidence and complied with proper legal standards. The ALJ had considered Napier's testimony, her limited treatment history for mental impairments, and the opinions of several psychologists. The ALJ found that Napier's mental impairments were not severe and that her physical impairments did not preclude her from performing her past work. The court also found that the ALJ adequately accounted for Napier's mental impairments in the RFC analysis.The Sixth Circuit affirmed the district court's judgment, concluding that the ALJ's findings were supported by substantial evidence and that the ALJ had followed the appropriate procedures in evaluating Napier's claims. View "Napier v. Commissioner of Social Security" on Justia Law

Montreal Morgan participated in a home invasion robbery that resulted in the death of Fabian Alvarez. Following the incident, the Department of Labor and Industries (L&I) paid $10,480 in benefits under Washington’s Crime Victims Compensation Act (CVCA) for Alvarez’s medical and funeral expenses. Morgan pleaded guilty to conspiracy to commit murder in the second degree and unlawful possession of a firearm in the second degree. At his restitution hearing, Morgan requested a reduction in the restitution amount due to mitigating factors, but the trial court believed it lacked discretion under RCW 9.94A.753(7) and ordered the full amount of restitution requested by the State.The trial court’s decision was affirmed by the Court of Appeals, which agreed that RCW 9.94A.753(7) does not afford trial courts discretion to impose less restitution than the amount of CVCA benefits paid. Morgan then petitioned for review, which was granted by the Supreme Court of the State of Washington.The Supreme Court of the State of Washington held that RCW 9.94A.753(7) does not allow a trial court discretion to modify the amount of restitution owed to L&I for CVCA benefits. The court emphasized that the statutory language is unambiguous and requires the court to order restitution in the amount of benefits paid by L&I. The court affirmed the Court of Appeals' decision and upheld Morgan’s restitution order, concluding that the trial court correctly interpreted the statute as mandating full restitution for CVCA benefits without discretion for reduction based on mitigating factors. View "State v. Morgan" on Justia Law

The plaintiff filed two successive applications for disability benefits under Title XVI of the Social Security Act. Her first application, alleging disability beginning June 24, 2017, was denied by an Administrative Law Judge (ALJ) on September 18, 2018. While appealing this denial to the district court, she filed a second application for benefits for a later period. Washington State Disability Determination Services (DDS) reviewed the second application and awarded benefits, determining she was disabled starting September 19, 2018, the day after the ALJ denied her first application.The district court partially ruled in her favor on the first application and remanded it for further proceedings. The Appeals Council remanded the case to the ALJ with instructions. On June 23, 2021, the ALJ reopened the second application and denied the benefits previously granted by DDS. The ALJ concluded that the plaintiff was disabled beginning July 14, 2020, on her first application. The district court held it lacked jurisdiction to review the ALJ’s reopening and denial of benefits on the second application.The United States Court of Appeals for the Ninth Circuit reversed the district court’s decision, holding that the district court had jurisdiction to review the ALJ’s reopening of the second application. The Appeals Council did not reopen the second application, and the ALJ’s reopening occurred more than two years after the award, which is only permissible in cases of fraud or similar fault. Finding no evidence of fraud or similar fault, the Ninth Circuit held that the ALJ erred in reopening and reversing the award of benefits on the second application. The court remanded for the district court to direct the agency to award benefits according to DDS’s decision. The Ninth Circuit affirmed the district court’s decision on the first application, concluding that the ALJ’s finding that the plaintiff was not disabled between June 24, 2017, and September 19, 2018, was supported by substantial evidence. View "NEVIN V. COLVIN" on Justia Law

Jason Kertz applied for social security disability benefits in October 2019, citing disabilities including PTSD, back and leg problems, and sleep apnea, with an onset date of March 16, 2018. His initial claim was denied, and an SSA administrative law judge (ALJ) also found him not disabled after a hearing. The SSA Appeals Council upheld this decision in February 2021. Kertz then hired attorney Nicholas Coleman to represent him in federal court. Coleman and Kertz agreed on a contingent-fee arrangement of 25% of any past-due benefits awarded.Coleman filed a civil action in the Eastern District of Arkansas, which resulted in the court remanding the case to the SSA for further proceedings. The district court awarded Coleman $5,426.08 in attorney’s fees under the Equal Access to Justice Act (EAJA). On remand, the ALJ issued a Fully Favorable Decision in December 2022, finding Kertz disabled since the alleged onset date. The SSA notified Kertz of his entitlement to $96,349.00 in past-due benefits, withholding 25% as potential attorney fees. Coleman then sought 25% of the past-due benefits as per the contingent-fee agreement.The United States District Court for the Eastern District of Arkansas granted Coleman’s motion for attorney’s fees in part, awarding $10,667.50 instead of the requested $24,087.25. The court found that the full 25% fee was not reasonable given the circumstances, including the limited time Coleman spent on the case and the lack of substantive court review due to the unopposed remand.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court did not abuse its discretion in reducing the fee award, as it appropriately considered the reasonableness of the fee in light of the services rendered and avoided a windfall to the attorney. View "Kertz v. Colvin" on Justia Law