Justia Public Benefits Opinion Summaries

The appellant claimed injury from a vaccine on December 6, 2019, and sought compensation under the National Vaccine Injury Compensation Program. He mailed his petition to the United States Court of Federal Claims by certified first-class mail ten days before the statutory deadline, but the petition arrived and was filed one day late due to an unexplained delay by the U.S. Postal Service. He requested equitable tolling, arguing that the late delivery by USPS and the effects of the COVID-19 pandemic were extraordinary circumstances preventing timely filing, and that he acted with reasonable diligence by mailing well before the deadline.A special master denied the request for equitable tolling, finding that the appellant was not reasonably diligent because he did not use a guaranteed or overnight delivery method, and that the postal delay did not qualify as an extraordinary circumstance. The United States Court of Federal Claims affirmed the special master’s finding regarding diligence and dismissed the petition, without addressing whether extraordinary circumstances were present.The United States Court of Appeals for the Federal Circuit reviewed the case. It found that the special master and the Court of Federal Claims applied the wrong legal standard by requiring more than reasonable diligence—specifically, by effectively mandating the use of guaranteed delivery methods and monitoring of tracking information. The Federal Circuit held that equitable tolling requires only reasonable, not maximum, diligence, and that mailing a petition ten days before the deadline by certified mail can satisfy that standard. The court reversed the finding that the appellant was not reasonably diligent, vacated the special master’s determination regarding extraordinary circumstances, and remanded to the Court of Federal Claims to determine whether an extraordinary circumstance justifies equitable tolling under the proper standard. View "CHITLIK v. HHS " on Justia Law

A veteran who served in the Marine Corps, including a tour in Vietnam, began experiencing fatigue and underwent a medical evaluation at a Veterans Affairs Medical Center in 2010. His blood tests showed elevated lymphocyte counts. However, VA physicians in Florida diagnosed him with monoclonal B-cell lymphocytosis (MBL), not chronic lymphocytic leukemia (CLL), and did not inform him of a CLL diagnosis. Years later, after his condition worsened and he relocated to Tennessee, a VA oncologist diagnosed him with CLL and retroactively opined that his medical records met the diagnostic criteria for CLL since 2010. The veteran then applied for VA disability compensation. The VA assigned a 100% disability rating with an effective date of January 29, 2016, the date his claim was filed.The veteran appealed, arguing for an earlier effective date due to the alleged misdiagnosis and failure to inform him about his CLL. The Board of Veterans’ Appeals partially granted his request, assigning an effective date of January 29, 2015, but declined to go earlier, finding that the law did not allow equitable considerations to affect the effective date under 38 U.S.C. § 5110. The veteran then appealed to the United States Court of Appeals for Veterans Claims, raising arguments that the VA should be equitably estopped from enforcing § 5110’s effective date restrictions, and that those restrictions were unconstitutional as applied to him. The Veterans Court affirmed the Board’s decision.On further appeal, the United States Court of Appeals for the Federal Circuit affirmed the Veterans Court. The Federal Circuit held that equitable estoppel cannot override the effective date limitations of 38 U.S.C. § 5110, and that § 7331 does not create a statutory precondition to enforcement of § 5110. It also held that the statute’s effective date limitations were not unconstitutional as applied to the veteran’s circumstances. View "LEY v. COLLINS " on Justia Law

After being discharged from employment as a painter in March 2024, the appellant applied for unemployment benefits. The Minnesota Department of Employment and Economic Development (DEED) determined that the appellant was ineligible for benefits due to employment misconduct and mailed a determination of ineligibility to his last known address on April 29, 2024, informing him of a 20-day appeal period. The appellant did not receive the determination within the allotted time because he was temporarily homeless following an eviction. He filed an appeal on June 20, 2024, after the 20-day deadline had passed, explaining his circumstances regarding late receipt of the notice.An unemployment law judge (ULJ) dismissed the appeal as untimely, stating there was no legal authority to consider the late appeal. The appellant requested reconsideration, reiterating his explanation and disputing the grounds for his discharge. The ULJ affirmed the dismissal as factually and legally correct. The appellant then petitioned the Minnesota Court of Appeals for a writ of certiorari. The Court of Appeals affirmed the ULJ’s dismissal, holding that there were no exceptions or extensions to the statutory appeal deadline under Minn. Stat. § 268.101, subd. 2(f).The Minnesota Supreme Court reviewed whether a ULJ may consider an explanation for a late appeal from a determination of ineligibility for unemployment benefits. The Court held that the statutory language is clear: a ULJ must dismiss an untimely appeal without discretion to consider mitigating circumstances or explanations for the late filing. As a result, the Supreme Court affirmed the decision of the Court of Appeals, confirming that the statutory appeal deadline is absolute and not subject to exceptions. View "Oslund vs. The Paint Genie, Inc." on Justia Law

Two individuals who were victims of terrorist attacks sponsored by Iran obtained judgments against Iran under the Foreign Sovereign Immunities Act’s terrorism exception and were deemed eligible for compensation from the United States Victims of State Sponsored Terrorism Fund. The Fund is financed by criminal penalties and forfeitures related to certain offenses involving state sponsors of terrorism. After British American Tobacco and its subsidiary agreed to pay over $629 million in criminal penalties and forfeitures for conspiracies involving illicit business with North Korean entities, the Department of Justice allocated only a small fraction of those proceeds to the Fund. The Department’s allocation was based on its interpretation that only proceeds from offenses with a direct nexus to a state sponsor of terrorism should be deposited.The United States District Court for the District of Columbia granted summary judgment for the Department of Justice, upholding its interpretation of the relevant statutory funding provision. The district court reasoned that only proceeds from transactions or conduct occurring while North Korea was designated as a state sponsor of terrorism should be deposited into the Fund, and that the Department’s allocation was consistent with statutory requirements.Upon appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the district court’s decision de novo. The Court of Appeals held that the Department of Justice erred in its allocation. The statutory language requires all proceeds from violations of IEEPA and TWEA, including conspiracy offenses charged under IEEPA, to be deposited into the Fund regardless of any nexus to a state sponsor of terrorism. Additionally, for related criminal conspiracies such as BAT’s bank fraud conspiracy, if the offense originated from doing business with a state sponsor of terrorism, all proceeds must be deposited into the Fund. The Court reversed the district court’s judgment and remanded with instructions to enter summary judgment for the plaintiffs. View "Englehardt v. Blanche" on Justia Law

The case concerns a veteran who served in the Army in Vietnam and Kuwait. He applied for disability benefits from the Department of Veterans Affairs (VA) in December 2011, specifically seeking compensation for hypertension, which he claimed was directly related to his military service. Supporting his claim, he provided personal statements and a letter from a flight surgeon detailing hypertension during deployment. The VA Regional Office denied his claim, and after a lengthy appeals process, the Board of Veterans’ Appeals granted him benefits for hypertension under the PACT Act, a law enacted in 2022 that provides presumptive service connection for certain conditions, including hypertension for Vietnam veterans exposed to Agent Orange. However, the Board did not address his original claim for direct service connection.After the Board’s decision, Mr. Hepler appealed to the Court of Appeals for Veterans Claims (“Veterans Court”), contending that the Board failed to adjudicate his direct service-connection claim for hypertension, which could have resulted in an earlier effective date for benefits. The Veterans Court dismissed his appeal as moot, reasoning that his entitlement to benefits under the PACT Act resolved the issue and any dispute over the effective date was a downstream matter requiring a separate appeal. Mr. Hepler’s motion for reconsideration was denied.Reviewing the case, the United States Court of Appeals for the Federal Circuit determined that the Veterans Court’s decision was incorrect. The Federal Circuit held that the Board was required to adjudicate the veteran’s direct service-connection claim, even after granting benefits under the PACT Act, because the claims are distinct and the direct claim could entitle the veteran to additional, earlier benefits. The Federal Circuit reversed and remanded, instructing the Veterans Court to require the Board to grant, deny, or remand the direct service-connection claim. View "HEPLER v. COLLINS " on Justia Law

An individual, born in 1937, assumed the identity of his younger brother, who died in infancy, to fraudulently obtain a second Social Security number and collect retirement benefits under both his own and his brother’s identities. Over the course of nearly two decades, he received Social Security payments in both names and also procured and used U.S. passports issued under his deceased brother’s identity. His scheme unraveled after a state motor vehicle official noticed similarities between two identification cards with different names but similar photos and addresses. Subsequent investigation revealed the use of both identities for benefits and travel, as well as submission of multiple passport applications with false information.A grand jury in the United States District Court for the District of Maine indicted the defendant on six counts, including identity theft, passport fraud, Social Security fraud, and mail fraud. At trial, the defendant contested the propriety of venue in Maine for two passport fraud counts and challenged the calculation of restitution. The district court submitted the venue question to the jury, which found venue proper for both passport counts and convicted him on all charges. He was sentenced to probation and ordered to pay $175,757 in restitution.Upon appeal, the United States Court of Appeals for the First Circuit reviewed the jury’s venue determinations and the restitution order. The court held that sufficient circumstantial evidence supported venue in Maine for both the false statement in the passport application and the use of a fraudulently obtained passport, applying the appropriate legal standards for each count. The court also found no abuse of discretion in the district court’s method for calculating restitution, concluding that the government met its burden of proof regarding the loss amount. The First Circuit affirmed both the convictions and the restitution order. View "US v. Gonzalez" on Justia Law

After her 18th birthday, a young woman with severe disabilities, requiring 24-hour care and living in a subacute facility since infancy, was placed under extended foster care as a nonminor dependent. She had no family contact and lacked the mental capacity to make independent decisions. Her county child welfare agency regularly submitted reports and transitional independent living plans, documenting her progress and confirming her continued eligibility for extended foster care. The agency recommended continued jurisdiction, especially while her application for supplemental security income was pending, and later reported plans for her care to be managed by a regional center as she approached adulthood.The Superior Court of San Bernardino County repeatedly found that she was making satisfactory progress toward her care goals and met the requirements to remain a nonminor dependent. The court ordered continued jurisdiction until, in a subsequent review, the agency recommended dismissal, citing the transition of her care to the regional center. Following a contested hearing, despite arguments from her counsel and guardian ad litem for continued court oversight, the juvenile court terminated jurisdiction. The court reasoned that ongoing jurisdiction was not in her best interest, finding no further benefit to her from county oversight given her new care arrangements.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the appeal. The court held that the juvenile court applied the wrong legal standard by terminating jurisdiction based on a subjective best interest determination instead of the statutory criteria. Under section 391, jurisdiction over a nonminor dependent may only be terminated if the nonminor does not wish to remain under jurisdiction, is not participating in a reasonable transitional plan, or cannot be located. None of these circumstances applied. The appellate court therefore reversed the termination order and directed reinstatement of jurisdiction. View "In re Violet S." on Justia Law

Several employee associations and a retired county employee challenged a resolution adopted by the Ventura County Employees’ Retirement Association (VCERA). The resolution limited the amount of cashed out leave that could be included in the calculation of “compensation earnable”—a key figure used to determine retirement benefits for so-called legacy members (employees hired before 2013) under the County Employees Retirement Law of 1937. The dispute centered on the California Public Employees’ Pension Reform Act of 2013 (PEPRA), which amended the law to exclude from pension calculations any leave cashout payments exceeding what may be “earned and payable in each 12-month period during the final average salary period,” regardless of when the payment is made. The controversy arose when a retired employee sought to have all 240 hours of his cashed out leave included in his final compensation period, even though county rules allowed only 200 hours to be cashed out per calendar year.The Santa Barbara County Superior Court granted summary adjudication in favor of VCERA, concluding that PEPRA’s section 31461(b)(2) was ambiguous but, as explained in the California Supreme Court’s earlier decision in Alameda County Deputy Sheriff’s Assn. v. Alameda County Employees’ Retirement Assn., the Legislature intended to curb “pension spiking” by imposing annual limits. The Second Appellate District, Division Six, affirmed this decision, interpreting the statute to mean that only leave cashouts within the annual limitation set by employment terms could be counted.The Supreme Court of California affirmed the Court of Appeal’s judgment. It held that section 31461(b)(2) of PEPRA excludes from pension calculations any cashed out leave that exceeds the applicable annual limit during the final compensation period, even if the period straddles two calendar years. This construction aligns with the statute’s purpose to prevent pension spiking and maintain the integrity and predictability of public pension systems. View "Ventura Cty Emp Ret Assn v. Crim J Atty Ret Assn Ventura Cty" on Justia Law

A hospice provider participated in the Medicare program and sought reimbursement for hospice services provided to several patients. Medicare, through its contractor, conducted a review and determined that a substantial number of the provider's claims did not meet the required coverage criteria, resulting in a demand for repayment of nearly $1 million. The contractor’s decision was partially reversed at the next level of administrative review for some claims, but a significant number were still denied. The provider pursued further administrative appeals, including a hearing before an administrative law judge (ALJ), where testimony and medical records were considered. The ALJ ultimately found that some additional claims were covered but upheld the denial of coverage for others, concluding that the provider was financially responsible for those denied claims and could not benefit from the statutory safe harbor.After the Medicare Appeals Council failed to resolve the provider’s appeal within the prescribed time, the provider sought judicial review in the United States District Court for the Northern District of Ohio. The district court affirmed the ALJ’s decision, agreeing with the denial of coverage for the disputed claims and with the determination that the provider was not entitled to the safe harbor protection.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed two issues: whether substantial evidence supported the ALJ’s denial of Medicare coverage for the claims, and whether the ALJ properly applied the Medicare statute’s safe harbor provision. The appellate court held that substantial evidence did support the denial of coverage. However, it determined that the ALJ had applied the wrong legal standard to the safe harbor inquiry. The Sixth Circuit clarified that the correct standard requires assessment of whether the provider reasonably interpreted the relevant Medicare guidance as covering the disputed claims. The court vacated the district court’s judgment as to the safe harbor issue and remanded with instructions to return the case to the ALJ for application of the correct safe harbor standard to each disputed claim. View "In Home Health, LLC v. Kennedy" on Justia Law

The plaintiff, who has a history of bipolar disorder, chronic pain due to orthopedic injuries, and an ear injury, applied for disability benefits in July 2020, alleging an inability to work since December 2019. Several consultative medical examiners assessed the plaintiff’s physical and mental impairments. While most concluded that the plaintiff was capable of routine, unskilled work, one psychologist, Dr. Pushkash, found that the plaintiff’s ability to concentrate and persist on tasks was markedly impaired due to chronic pain and psychological symptoms, though his cognitive abilities were otherwise unremarkable.After his claim was denied by Wisconsin’s disability agency, both initially and on reconsideration, the plaintiff requested a hearing before an Administrative Law Judge (ALJ). The ALJ found the plaintiff was not disabled, deeming Dr. Pushkash’s opinion “generally unpersuasive” for reasons including the one-time nature of the evaluation and the psychologist’s comments on physical pain. The Appeals Council denied review, making the ALJ’s decision final. The plaintiff then sought review in the United States District Court for the Western District of Wisconsin, which affirmed the ALJ’s decision, focusing on the ALJ’s treatment of Dr. Pushkash’s opinion.On appeal, the United States Court of Appeals for the Seventh Circuit held that while the ALJ’s analysis of Dr. Pushkash’s opinion contained several legal errors—such as failing to properly address required regulatory factors and inconsistently assessing medical opinions—these errors were harmless. The court concluded that, even if Dr. Pushkash’s opinion were fully credited, the plaintiff would not meet the regulatory criteria for disability, as he did not have the requisite number of “marked” or “extreme” limitations in areas of mental functioning. Therefore, the Seventh Circuit affirmed the judgment of the district court. View "Liapis v Bisignano" on Justia Law