Justia Public Benefits Opinion Summaries

The plaintiff applied for supplemental security income, asserting that a combination of physical and mental impairments, including obesity, blood clots, migraines, high blood pressure, agoraphobia, anxiety, and depression, rendered her unable to work. She had received special-education services in high school and subsequently attempted, but did not complete, a cosmetology program. Her anxiety and agoraphobia were managed with medication, and treatment records frequently noted normal mental status. In connection with her claim, she was evaluated by a psychological consultant who diagnosed agoraphobia and opined severe impairment in her ability to interact and tolerate work-related stress. State-agency consultants reviewed the record and found moderate or lesser limitations, concluding she could perform simple, repetitive tasks with limited social interaction.An Administrative Law Judge (ALJ) denied her claim following a hearing, finding she retained the residual functional capacity to perform a range of light, unskilled work, and relying on testimony from a vocational expert. The ALJ found the psychological consultant’s opinion less persuasive than those of the state-agency reviewers, and determined the plaintiff could stand and walk for more than four hours per workday. The ALJ identified jobs she could perform even with a four-hour standing and walking limitation. The Appeals Council denied review, and the United States District Court for the Western District of North Carolina granted summary judgment to the Commissioner.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s judgment under a deferential substantial-evidence standard. The court held that the ALJ applied the correct legal standards, adequately explained her evaluation of medical opinions and educational findings, and that substantial evidence supported those conclusions. Any error in the standing-and-walking finding was deemed harmless because the occupations identified at step five accommodated a four-hour limitation. The court affirmed the district court’s judgment. View "Calhoun v. Commissioner of Social Security" on Justia Law

Jessica Stuart was convicted of health care fraud and using false identification after she falsely claimed to be a Board-Certified Behavioral Analyst, rendering services to children with autism and causing significant financial losses to her employer and Medicaid. Her criminal history included multiple instances of fraud and larceny, such as issuing bad checks, stealing from individuals with whom she resided, and manipulating payments for personal gain. After serving her sentence, Stuart’s supervised release was marked by additional violations, including failing to make restitution payments, moving without approval, committing new frauds involving food stamps and unemployment benefits, and failing to report police contact.The United States District Court for the District of Connecticut initially sentenced Stuart to incarceration and supervised release. When she violated conditions of her supervised release, the court, now presided over by Judge Nagala, imposed a new special condition authorizing the Probation Office to notify third parties—including employers, potential employers, and others to whom Stuart might pose a risk—of her criminal history and past conduct. Stuart objected, arguing the condition improperly delegated judicial authority to the Probation Office by granting it sole discretion to determine who qualifies as a third party at risk.The United States Court of Appeals for the Second Circuit reviewed the challenge. Applying an abuse of discretion standard and reviewing legal questions de novo, the court held that the district court had sufficiently limited the Probation Office’s discretion. The condition was found permissible because it was rooted in Stuart’s varied and opportunistic risk profile, and the court had provided enough guidance to constrain arbitrary use of delegated authority. The Probation Office’s role was determined to be execution, not imposition, of the condition. Accordingly, the Second Circuit affirmed the judgment of the district court. View "United States v. Stuart" on Justia Law

A minor covered by MaineCare sustained an arm and elbow injury requiring medical treatment, for which MaineCare paid $34,078.70, though providers billed much more. The minor’s mother sued two third-party tortfeasors, seeking $375,000 in damages, including over $200,000 in medical bills. The claim was settled for $160,000, less than half the original claimed value. The Department of Health and Human Services asserted a lien for the full amount it paid. The mother filed suit against the Department, arguing that the Department’s recovery should be limited to the proportion of the settlement attributable to medical expenses, using a formula derived from Arkansas Department of Health and Human Services v. Ahlborn, 547 U.S. 268 (2006).The Androscoggin County Superior Court entered summary judgment for the plaintiff, applying the percentage of total damages recovered (42.67%) to the amount the Department paid, thereby reducing the Department’s recovery to $14,540.25. The Department appealed, arguing that the calculation should be based on the entire amount billed for medical expenses, not the amount paid, and that the allocation formula was not appropriate without further factual findings.The Maine Supreme Judicial Court reviewed the case and vacated the judgment. The court held that, when a settlement does not allocate amounts between medical expenses and other damages and the parties do not stipulate to an allocation, the trial court must conduct an individualized, fact-intensive evidentiary hearing to determine what portion of the settlement is reasonably attributable to medical expenses. Only that portion is available for the Department’s recovery, limited to the amount it actually paid. The court rejected the use of a rigid formula or arbitrary reduction and remanded for further proceedings. View "Lynne v. Department of Health and Human Services" on Justia Law

While receiving unemployment benefits, the claimant worked part-time for Terrace Home Health Boise, LLC and reported her earnings to the Idaho Department of Labor. After an audit, the Department determined that she had underreported her earnings in four weekly certifications, resulting in an overpayment of $228. The claimant explained the discrepancies by noting differences in pay periods and her method of calculating wages, as well as possible reporting mistakes due to not recognizing partial hour increments. Terrace Home Health initially reported some errors, but those were subsequently corrected. The Department concluded that the overpayment was not intentional and did not assess penalties, but demanded repayment and advised the claimant of her right to appeal and request a waiver.Following the Department’s determination and subsequent denial of her waiver request, the claimant appealed to the Department’s Appeals Bureau, which held a telephonic hearing. The claimant asserted that the errors were caused by her employer’s reporting and objected to the deduction from her benefit payment. The appeals examiner found that the overpayment resulted from the claimant’s own misreporting and denied her appeal. The claimant further appealed to the Idaho Industrial Commission, reiterating her arguments and raising concerns about the fairness of the hearing. The Commission concluded that the overpayment was due to her error, not Department or employer error, making her ineligible for a waiver, and found no evidence that the hearing was conducted improperly.Upon review, the Supreme Court of the State of Idaho affirmed the Industrial Commission’s decision. The Court held that the claimant forfeited any assignment of error because her appellate briefing failed to comply with Idaho Appellate Rule 35(a)(6), requiring argument and citations to legal authority and the record. As a result, the Commission’s denial of the waiver and affirmation of the repayment obligation was upheld. View "PHELPS v. COMMUNITY HEALTH CLINICS, INC." on Justia Law

The plaintiff experienced ongoing pain, numbness, and tingling in both hands and upper extremities, which led her to stop working her retail job in June 2016 following surgeries on both hands and forearms. Despite subsequent surgeries and ongoing treatment—including physical therapy and additional procedures on her shoulders—she continued to report symptoms, though medical records at times showed normal strength and range of motion. Throughout this period, she reported being able to perform various daily activities, such as driving, doing housework, and caring for family members, though some medical providers imposed restrictions on lifting weight.The plaintiff applied for disability insurance benefits for a closed period from June 3, 2016 to August 5, 2021. An administrative law judge (ALJ) reviewed her application, considering her medical records, her function report, and opinions from treating and reviewing physicians. The ALJ determined that she had the residual functional capacity to perform sedentary work, which allows for lifting up to ten pounds, and found that she could frequently handle, finger, and reach for objects. Based on this assessment and testimony from a vocational expert regarding available jobs, the ALJ concluded that the plaintiff was not disabled. The United States District Court for the Eastern District of Missouri affirmed the ALJ’s decision.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The Eighth Circuit held that the ALJ’s determination was supported by substantial evidence, particularly in the evaluation and reliance on a medical opinion that was consistent with the claimant’s activities and medical records. The court concluded that the ALJ’s residual functional capacity finding and the denial of disability benefits fell within the permissible zone of choice and therefore affirmed the judgment. View "Post v. Bisignano" on Justia Law

A claimant worked as an adjunct professor for a college that operated on a trimester system, offering fall, spring, and summer terms. For many years, the claimant taught during the spring and fall terms, but not consistently during the summer. In 2024, the claimant had contracts to teach in the spring and fall terms but was not offered a summer teaching assignment. After the spring term concluded, the claimant applied for unemployment benefits for the summer period.A claims adjudicator initially denied the request, finding that the claimant had reasonable assurance of employment for the next “regularly scheduled academic term”—the fall—even though the summer intervened. The claimant appealed, and an Administrative Law Judge affirmed the denial, citing the claimant’s established pattern of not teaching in the summer. The claimant then appealed to the Vermont Department of Labor Employment Security Board, which reversed the denial. The Board concluded that because the claimant did not have reasonable assurance of employment for the successive term—summer 2024—he was eligible for unemployment benefits during that period.The Vermont Supreme Court reviewed the case and applied a de novo standard to the statutory interpretation at issue. The Court held that under 21 V.S.A. § 1343(c)(1), unemployment benefits are not payable to employees of educational institutions for periods between two regular, but not necessarily successive, terms if there is an agreement to work both terms and reasonable assurance of continued employment. The Court found that the claimant had such an agreement and reasonable assurance for the spring and fall terms, and that the summer period fell within the statutory exclusion. Therefore, the Vermont Supreme Court reversed the Board’s decision, holding that the claimant was not eligible for unemployment benefits for the summer term under the statute. View "Vermont State Colleges v. Department of Labor" on Justia Law

A divorced couple with a special-needs adult daughter became involved in a dispute over the calculation of child and spousal support. The father, after losing his high-paying job, sought to reduce his support obligations. The mother, who is the primary caregiver for their daughter and works part-time as an instructional aide and as an in-home caregiver for the daughter through the In Home Supportive Services (IHSS) program, objected. She argued that her IHSS payments should not be counted as her income in calculating support, and she contended that the father’s substantial assets and lifestyle indicated that his actual income was higher than reported.The Superior Court of San Diego County consolidated the parties’ motions and held a hearing. The court determined that, although the daughter had reached adulthood, she remained incapacitated and was entitled to continued support. The court calculated the father’s income based on unemployment benefits and later self-employment, and the mother’s income as including both her instructional aide wages and her IHSS payments. The court found that, due to insufficient evidence of the father’s assets’ value or liquidity, it would not include them as part of his income. The court adjusted the father’s support obligations downward but did not terminate them. The mother appealed these orders.The California Court of Appeal, Fourth Appellate District, Division One, affirmed the lower court’s orders. The appellate court held that IHSS payments received by a parent for providing care to their child are not excluded from gross income under Family Code section 4058(c), as the child, not the parent, is the statutory recipient of the needs-based public assistance. The court also held that the trial court did not abuse its discretion in determining the father’s income and deciding not to impute additional income from his assets. View "Marriage of R.M. and P.N." on Justia Law

A former underground coal miner developed severe respiratory problems, including chronic cough and significant limitations in daily activities, following nearly 12 years of employment in West Virginia coal mines. After his symptoms worsened post-employment, he filed a claim for benefits under the Black Lung Benefits Act in 2020. Medical testing revealed persistent lung function impairment, and four pulmonary specialists—two for the miner and two for his former employer—offered differing opinions on the cause of his disability. The miner’s experts attributed his impairment to legal pneumoconiosis resulting from coal mine dust exposure, while the company’s experts diagnosed asthma unrelated to mining.A United States Department of Labor administrative law judge (ALJ) heard the case. The parties stipulated to the miner’s work history, and the company was named the responsible operator. The ALJ found the miner’s experts’ opinions more persuasive, particularly because they addressed the regulatory definitions and considered the possibility that coal dust exposure worsened his condition. The ALJ concluded the miner had legal pneumoconiosis arising from his coal mine employment, was totally disabled, and that pneumoconiosis substantially contributed to his disability. The company’s experts were found less persuasive for not adequately addressing the regulatory definition or the potential contribution of coal dust. The Benefits Review Board (BRB) affirmed the ALJ’s decision, concluding that substantial evidence supported all findings.The United States Court of Appeals for the Fourth Circuit reviewed the company’s petition. The court held that the ALJ and BRB did not err in their factual findings or legal analysis. It found sufficient evidence that the miner had legal pneumoconiosis caused by coal mine employment and that the disease substantially contributed to his total disability. The Fourth Circuit denied the petition for review, affirming the award of black lung benefits to the miner. View "Central Appalachian Coal Company v. DOWCP" on Justia Law

The claimant, a veteran who served in the United States Army in 1968, sought service-connected disability benefits for bilateral hearing loss. After applying for benefits in 2013, he was ultimately awarded service connection by the Department of Veterans Affairs (VA), but assigned a non-compensable (0%) disability rating. The claimant challenged this rating, contending that awarding a 0% rating for a service-connected disability contradicts statutory provisions that specify ten grades of disability (from 10% to 100%) for compensation purposes.The Board of Veterans’ Appeals denied his request for an initial compensable rating. The claimant appealed to the United States Court of Appeals for Veterans Claims, arguing that the relevant statutes required the Board to award at least a 10% rating and that the Secretary’s implementation of a 0% rating exceeded statutory authority. The Veterans Court determined it lacked jurisdiction to review substantive challenges to the rating schedule established by the Secretary under 38 U.S.C. § 1155, as expressly barred by 38 U.S.C. § 7252(b). The court concluded it could not consider the claimant’s argument because it amounted to a challenge to the validity of the rating schedule.On appeal, the United States Court of Appeals for the Federal Circuit held that, under its own jurisdictional statute (38 U.S.C. § 7292) and binding precedent in Wingard v. McDonald, it also lacked jurisdiction to review substantive statutory challenges to the VA’s rating schedule, including the claimant’s argument against the 0% disability rating. The Federal Circuit dismissed the appeal for lack of jurisdiction, affirming that such challenges are precluded from judicial review by both the Veterans Court and the Federal Circuit. No costs were awarded. View "GORDON v. COLLINS " on Justia Law

Three individuals residing in Missouri, each of whom had significant difficulties applying for or recertifying their eligibility for SNAP benefits due to problems with the Missouri Department of Social Services (DSS) call center and application procedures, brought a lawsuit. They alleged wrongful denial of benefits and failure to provide reasonable accommodations for disabilities. All three eventually received SNAP benefits after joining the lawsuit but expected to need continued assistance. Empower Missouri, a nonprofit organization, also joined the suit, asserting that DSS’s practices forced it to divert resources to address these systemic problems.In the United States District Court for the Western District of Missouri, the plaintiffs claimed violations of specific provisions of the SNAP Act, the Due Process Clause of the Fourteenth Amendment, and the Americans with Disabilities Act (ADA), seeking declaratory and injunctive relief. The district court found that all plaintiffs had standing, rejected arguments that their claims were moot, and determined that DSS’s practices violated their due process and ADA rights. The court granted summary judgment in favor of the plaintiffs and issued a broad remedial order requiring systemic changes to DSS’s SNAP administration, including detailed operational requirements and ongoing reporting.On appeal, the United States Court of Appeals for the Eighth Circuit held that the individual plaintiffs had standing for their due process and ADA claims, but Empower Missouri did not, as its advocacy expenditures alone did not confer standing. The court determined that the SNAP Act provisions cited did not create individual rights enforceable under 42 U.S.C. § 1983 or an implied private right of action. It affirmed the district court’s summary judgment for the individual plaintiffs on their due process and ADA claims, except for one plaintiff’s ADA claim, which lacked evidence of a requested accommodation. The Eighth Circuit vacated the district court’s permanent injunction, finding it overbroad and issued without proper consideration of adequate legal remedies, and remanded for further proceedings. View "Holmes v. Bax" on Justia Law