Justia Public Benefits Opinion Summaries

The plaintiff, Mya Noelia Fallon, applied for Supplemental Security Income (SSI) under the Social Security Act, citing epileptic seizures and cognitive and behavioral limitations. Her application included assessments from her neurologist, Dr. Joseph Drazkowski, and licensed professional counselor (LPC) Terry Galler, who noted significant cognitive impairments and anxiety disorders. An Administrative Law Judge (ALJ) found Fallon not disabled, giving minimal weight to the opinions of Dr. Drazkowski and LPC Galler, and discrediting other medical and lay testimony.The United States District Court for the District of Arizona partially reversed the ALJ's decision, finding errors in the discounting of some witnesses but agreeing with the ALJ's assessment of Dr. Drazkowski's and LPC Galler's opinions. The case was remanded for further consideration. On remand, the ALJ again found Fallon not disabled, incorporating the prior evaluations. Fallon appealed, and the district court affirmed the ALJ's decision, refusing to revisit its prior conclusions about the medical opinions based on the law-of-the-case doctrine.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the law-of-the-case doctrine applies in the social security context, meaning that the district court did not abuse its discretion by refusing to reconsider the evaluations of Dr. Drazkowski and LPC Galler. The court explained that a social-security applicant has two options to preserve the right to appeal: immediately appeal the remand order or proceed on remand, understanding that the district court may decline to revisit settled issues. The Ninth Circuit affirmed the district court's decision, noting that Fallon forfeited her ability to challenge the evaluations by not raising the issue in her first appeal. View "FALLON V. DUDEK" on Justia Law

Dennis Jones, a 42-year-old part-time grocery store cashier, applied for Social Security disability benefits, claiming that conditions related to his premature birth, including a cerebral hematoma, had worsened and prevented him from working full-time. The Social Security Administration denied his application, and Jones requested an administrative hearing. An Administrative Law Judge (ALJ) found that Jones had the residual functional capacity to perform light work with certain limitations and concluded that he was not disabled.The United States District Court for the Northern District of Illinois affirmed the ALJ's decision. Jones then appealed to the United States Court of Appeals for the Seventh Circuit, arguing that the ALJ failed to properly evaluate a statement from Dr. James Runke, a consultative examiner, which Jones contended was a medical opinion.The Seventh Circuit agreed with Jones that Dr. Runke's statement, which indicated that Jones's pain and joint strain limited him to working 20 hours per week, constituted a medical opinion under the 2017 revised regulations. However, the court held that the ALJ was not required to evaluate the persuasiveness of this medical opinion because it addressed an issue reserved to the Commissioner of Social Security—whether Jones was capable of performing regular or continuing work. Consequently, the ALJ had no obligation to provide an analysis of Dr. Runke's statement. The Seventh Circuit affirmed the district court's decision, upholding the denial of benefits. View "Jones v Dudek" on Justia Law

William Dexter Lucas was involved in schemes to fraudulently obtain small-business loans from the government and vehicle loans from private institutions. He pleaded guilty to conspiracy to commit bank and wire fraud and waived his right to appeal. His presentence investigation report (PSR) included details of his fraudulent activities and mentioned allegedly fraudulent social security benefits he had been receiving. At sentencing, the district court ordered Lucas to pay restitution to both the private institutions and the Social Security Administration (SSA). Lucas appealed his sentence, challenging the restitution orders for the vehicle loans and social security benefits.The United States District Court for the Southern District of Texas initially handled the case. Lucas objected to the PSR's restitution calculations, arguing that the vehicle loans restitution was ordered to the wrong victim and incorrectly calculated, and that the social security benefits restitution was improper because he was entitled to the benefits and the alleged fraud was not part of the same scheme as the offenses in his indictment. The district court recalculated the vehicle loans restitution but upheld the SSA restitution, finding that Lucas's statement to the SSA was fraudulent and that the SSA fraud was part of the same conduct as the fraud alleged in the indictment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the SSA restitution was erroneous because the SSA fraud was not part of the same scheme or conspiracy as the offenses in the indictment. The court affirmed the vehicle loans restitution, finding that Lucas's challenge to the calculation was barred by his appeal waiver and that the dealerships were proper victims. The court affirmed the vehicle loans restitution but vacated the SSA restitution award. View "United States v. Lucas" on Justia Law

Two elderly individuals, Ms. Penelope Lamle and Ms. Maxine Houston, applied for Medicaid but faced delays and additional questions from the Oklahoma Department of Human Services, allegedly directed by attorney Susan Eads. They refused to answer these questions and subsequently sued, seeking an expedited decision, payment of Medicaid benefits, and damages. Both applicants died during the litigation, and their estates were substituted as parties in the appeal.The United States District Court for the Western District of Oklahoma dismissed the action with prejudice, citing the plaintiffs' failure to state a valid claim. However, the court was unaware that the applicants had died while the action was pending.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found that the claims for an injunction became moot when the agency denied benefits and the applicants died. The court noted that the requested relief would no longer benefit the estates, as the Oklahoma Department of Human Services had already denied the applications. The court also held that the Eleventh Amendment barred the requested retrospective relief. Consequently, the court remanded the case to the district court with instructions to vacate the judgment on the claim for a prospective injunction and dismiss it without prejudice.Regarding the claim against Ms. Eads in her individual capacity, the Tenth Circuit held that she was entitled to qualified immunity. The court found that the plaintiffs did not allege facts showing the violation of a clearly established right. As a result, the court affirmed the dismissal with prejudice of the claim for damages against Ms. Eads. View "Lamle v. Eads" on Justia Law

Christine Swiecichowski worked in a warehouse for over thirty years until 2018, when she quit due to increasing symptoms and pain from fibromyalgia, depression, issues with her right arm and wrist, and spinal disorders. She applied for disability benefits in October 2018, claiming she was disabled from October 16, 2018. Her application and testimony described debilitating pain that limited her ability to work and perform daily activities.The Administrative Law Judge (ALJ) denied her application in June 2020, following the Social Security Administration's five-step process for determining disability. The ALJ found that Swiecichowski had severe impairments, including fibromyalgia, but concluded that none were automatically disabling. The ALJ determined that her residual functional capacity (RFC) allowed her to perform light work with some restrictions. The ALJ discounted her subjective complaints of pain, citing mixed clinical findings and her ability to perform some daily activities. The Appeals Council denied her request for review, making the ALJ's decision final. The United States District Court for the Eastern District of Wisconsin affirmed the ALJ's decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the ALJ did not adequately follow the Social Security Administration's guidance on evaluating fibromyalgia, which requires a longitudinal review of the claimant's symptoms due to their waxing and waning nature. The ALJ's decision did not sufficiently consider the numerous medical visits and reports of pain over time. The court vacated the judgment affirming the denial of benefits and remanded the case for further proceedings consistent with its opinion. View "Swiecichowski v Dudek" on Justia Law

A group of foster children challenged the Office of Children’s Services (OCS) for using their federal Social Security benefits to reimburse itself for foster care costs. The children claimed this practice violated their due process and equal protection rights under the Alaska Constitution and sought restitution. The Superior Court of Alaska found a due process violation and ordered OCS to notify foster children about its practice regarding Social Security benefits. However, the court rejected the equal protection and restitution claims, deeming them preempted by federal law.The Superior Court held that OCS violated due process by not informing foster children about their Social Security benefits and the potential financial advantages of having a private representative payee. The court ordered OCS to provide notices explaining the concept of a representative payee, the consequences of OCS being the payee, and the possibility of proposing an alternative payee. OCS argued that complying with the notice order would violate federal privacy laws, but the court modified its order to address these concerns.The Supreme Court of Alaska reviewed the case and affirmed the Superior Court’s conclusions. The Supreme Court held that the due process claim and the court’s notice order were not preempted by federal law. The court determined that foster children have a property interest in knowing about their Social Security benefits and the ability to nominate a private payee. The court found that OCS’s systematic practice of using benefits to reimburse itself without notice created a high risk of depriving children of their rights.The Supreme Court also held that the equal protection claim was preempted because it would conflict with federal regulations governing the use of Social Security benefits. The court concluded that OCS’s practice of using benefits for foster care costs was permissible under federal law. Finally, the court rejected the proposed remedies of disgorgement and creating a trust, as they would constitute impermissible attachments on federal benefits and were preempted by federal law. View "State of Alaska, Department of Health and Social Services v. Z. C." on Justia Law

The plaintiff, Afaf Beshay Malak, applied for disability insurance benefits (DIB) in 2021, citing several disabilities including pinched nerves, osteoarthritis, fibromyalgia, and chronic headaches. Her application was denied initially and upon reconsideration by disability examiners. Malak then had a hearing before an Administrative Law Judge (ALJ), who followed the five-step evaluation process for disability claims. The ALJ determined that Malak had severe impairments but did not meet the criteria for a listed impairment. The ALJ assessed Malak’s Residual Functional Capacity (RFC) and found she could perform sedentary work with certain limitations. The ALJ concluded that Malak could perform her past work as a financial institution manager and other jobs in the national economy, thus finding her not disabled.Malak appealed the ALJ’s decision to the Appeals Council, which denied her request for review, making the ALJ’s decision the final decision of the Commissioner of Social Security. Malak then appealed to the district court, which affirmed the ALJ’s denial of her DIB claim. Malak subsequently appealed to the United States Court of Appeals for the Eleventh Circuit.The Eleventh Circuit reviewed the case to determine if the ALJ’s decision was supported by substantial evidence. Malak argued that the ALJ failed to consider her medically related absences and the side effects of her treatments. The court held that the ALJ is not required to consider the time needed for medical appointments when determining RFC, as RFC assessments focus on functional limitations caused by medically determinable impairments. The court also found that the ALJ properly considered the effectiveness and side effects of Malak’s treatments, noting that the medical evidence showed positive responses to treatments without significant side effects. The Eleventh Circuit affirmed the district court’s decision, upholding the denial of Malak’s DIB claim. View "Malak v. Commissioner of Social Security" on Justia Law

Paula S. Linden applied for Social Security benefits online in September 2014 at the age of 62, which was before her full retirement age of 66. As a result, she received smaller monthly payments than she would have if she had waited until 66. Linden claimed that she applied early based on misinformation from the Social Security Administration (SSA), which allegedly told her that she would receive the same benefits as if she had applied at 66. She sought to have her benefits recalculated as if she had applied at 66.The SSA denied her request, both initially and upon reconsideration. An Administrative Law Judge (ALJ) also ruled against her, stating that the statutory provision she cited, 42 U.S.C. § 402(j)(5), only applied to individuals who failed to apply for benefits due to misinformation. The ALJ also found insufficient evidence that Linden received misinformation from the SSA. The Appeals Council denied her request for review. Linden then filed a complaint in the United States District Court for the Eastern District of Michigan, which granted summary judgment in favor of the SSA and denied Linden’s motion for summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the plain text of 42 U.S.C. § 402(j)(5) precluded Linden’s recovery because the statute only applies to individuals who failed to apply for benefits due to misinformation. Since Linden did apply for benefits, she did not meet the statutory requirement. The court also found that the SSA’s regulations supported this interpretation. Additionally, the court noted that even if there was misinformation, it would not change the outcome because Linden did not fail to apply for benefits. Therefore, the court affirmed the district court’s decision. View "Linden v. Comm'r of Soc. Sec." on Justia Law

Kenneth Pontz was convicted by a jury of violating a federal embezzlement statute, 18 U.S.C. § 641, by misrepresenting his financial situation to obtain public benefits over an eight-year period. The government presented evidence that Pontz had received Supplemental Security Income (SSI) benefits by falsely claiming he lived alone, while he actually lived with his wife, who received Social Security Disability Insurance (SSDI) benefits. Pontz's misrepresentations allegedly began in 2004 and continued until 2020.The United States District Court for the District of Massachusetts denied Pontz's motion to dismiss the indictment, which argued that the statute of limitations barred charges for conduct occurring before June 16, 2017. The district court ruled that § 641 embezzlement was a "continuing offense," allowing the government to charge Pontz for conduct dating back to 2014. At trial, the court admitted testimony from an SSA employee, Luis Aguayo, as lay opinion under Federal Rule of Evidence 701, despite Pontz's objections that it was based on technical knowledge requiring expert testimony.The United States Court of Appeals for the First Circuit reviewed the case and held that § 641 embezzlement is not a continuing offense under the standard established in Toussie v. United States. The court found that the nature of embezzlement does not involve a renewed, daily threat of harm once the elements of the crime are complete. Consequently, the government could not charge Pontz for embezzlement occurring more than five years before his indictment. The court vacated the restitution and forfeiture orders and remanded to the district court to determine the appropriate remedy for the statute-of-limitations error. The court upheld the district court's evidentiary rulings regarding Aguayo's testimony. View "United States v. Pontz" on Justia Law

John Hudnall, a former financial advisor, applied for disability benefits under the Social Security Act, claiming he had been unable to work since May 1, 2015, due to major depressive disorder, anxiety, and insomnia. His application included a function report from his wife, Miyuki Sato, detailing his limitations in daily activities and self-care. Despite this, the Social Security Administration denied his application and request for reconsideration. Hudnall then sought a hearing before an Administrative Law Judge (ALJ), who also denied his claim, finding him not disabled based on medical evidence and Hudnall's self-reported activities, without explicitly addressing Sato's lay evidence.Hudnall appealed to the United States District Court for the Northern District of California, which granted summary judgment in favor of the Social Security Administration. Hudnall then appealed to the United States Court of Appeals for the Ninth Circuit.The Ninth Circuit reviewed the case and affirmed the district court's judgment. The court held that under the Social Security Administration's new regulations, effective March 27, 2017, ALJs are no longer required to provide germane reasons for discounting lay witness testimony. The court found that these regulations, which state that ALJs are not required to articulate how they considered evidence from nonmedical sources, are within the Commissioner of Social Security's broad authority and are not arbitrary and capricious. Consequently, the ALJ did not err in discounting Sato's evidence without explanation. The court resolved all other issues in a concurrently filed memorandum disposition. View "HUDNALL V. DUDEK" on Justia Law