Justia Public Benefits Opinion Summaries

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In 2009-2011, Hernandez sustained on-the-job injuries and received medical treatment. In 2016, she filed a voluntary Chapter 7 bankruptcy petition and reported unsecured claims held by three health care providers to whom she owed $28,709.60, $58,901.20, and $50,161.26 respectively. She reported minimal assets: $1300 in bank accounts and her pending workers’ compensation claim, valued at $31,000. Two days after filing her petition, Hernandez settled her workers’ compensation claim for $30,566.33 without consulting the bankruptcy trustee. She believed the settlement was exempt under section 21 of the Workers’ Compensation Act (820 ILCS 305/21). That statute provides: “No payment, claim, award or decision under this Act shall be assignable or subject to any lien, attachment or garnishment, or be held liable in any way for any lien, debt, penalty or damages….” The health care providers objected; the district court ruled in their favor. The Illinois Supreme Court answered a question of Illinois law certified by the Seventh Circuit: After the 2005 amendments to section 8 of the Workers’ Compensation Act and the enactment of section 8.2 of the Act, section 21 of the Act does exempt the proceeds of a workers’ compensation settlement from the claims of medical-care providers who treated the illness associated with that settlement or injury. View "In re Hernandez" on Justia Law

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After the plaintiffs’ disability claims were denied by ALJs employed by the Social Security Administration (SSA), the Supreme Court held in Lucia v. SEC (2018), that ALJs in the Securities and Exchange Commission (SEC) exercised “significant discretion” in carrying out “important functions” and were required, under the Appointments Clause, to be appointed by the President, a court of law, or the head of a department. Because the SEC ALJs were not so appointed, the petitioner there was entitled to a new hearing. When Lucia was decided, the plaintiffs were already in the process of challenging the SSA’s denial of their claims in the district court and demanded new hearings on the ground that the SSA ALJs were unconstitutionally appointed. The Acting Commissioner of SSA quickly reappointed the administrative judges but argued that the plaintiffs were not entitled to relief because they had not previously presented their Appointments Clause challenges to their ALJs or the Appeals Council and had not exhausted those claims before the agency. The district court declined to require exhaustion, vacated the agency’s decisions, and remanded for new hearings. The Third Circuit affirmed. Both the characteristics of the SSA review process and the rights protected by the Appointments Clause favor resolution of these claims on the merits, so exhaustion is not required in this context. View "Cirko v. Commissioner Social Security" on Justia Law

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Young, diagnosed with emphysema in 2002, had worked in coal mines for 19 years, retiring from Island Creek Coal in 1999. During and after work, Young would often cough up coal dust. For 35 years, Young smoked at least a pack of cigarettes a day. Young sought benefits under the Black Lung Benefits Act, 30 U.S.C. 902(b). Because Young had worked for at least 15 years as a coal miner and was totally disabled by his lung impairment, he enjoyed a statutory presumption that his disability was due to pneumoconiosis. If Young was entitled to benefits, Island Creek, Young’s last coal-mine employer, would be liable. After reviewing medical reports, the ALJ awarded benefits. The Benefits Review Board affirmed, noting that if there was any error in the ALJ’s recitation of the standard, that error was harmless. The Sixth Circuit denied a petition for review, first rejecting an Appointments Clause challenge as waived. The ALJ did not err by applying an “in part” standard in determining whether Island Creek rebutted the presumption that Young has legal pneumoconiosis. To rebut the “in part” standard, an employer must show that coal-mine exposure had no more than a de minimis impact on a miner’s lung impairment. The ALJ reasonably weighed the medical opinions and provided thorough explanations for his credibility determinations. View "Island Creek Coal Co. v. Young" on Justia Law

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In 2010 San Diego Sherriff’s Deputy Collier died following an accident while on duty. Collier owned a house together with his fiance, Li, who was also designated as Collier’s beneficiary for his retirement benefits and as a dependent for purposes of workers’ compensation. The two were to have been married three months after the date of Collier’s death; Collier had repeatedly stated, including on a video, that he had made arrangements for Li to be taken care of in the event of his death. Stamp, Collier’s former girlfriend, was named as the beneficiary of his life insurance. Stamp and Li agreed to split the proceeds; Li received $560,920 and Stamp received $25,000. The Bureau of Justice Assistance denied Li’s claim for benefits under the Public Safety Officers’ Benefits Act, 34 U.S.C. 10281, because Li was not the designated beneficiary on Collier’s life insurance policy. The Federal Circuit affirmed. Rejecting Li’s argument that the Bureau should have considered the “totality of the circumstances,” the court stated that Li was not the designated life insurance beneficiary. California law requires strict compliance with the requirement of a policy to change the beneficiary; Collier’s policy required a written designation. There was no written designation and none of the exceptions apply. View "Li v. Department of Justice" on Justia Law

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Prater was denied Social Security Disability Insurance benefits when she was 47-years-old and weighed about 400 pounds at 64 inches tall. X-rays showed mild-to-moderate degenerative joint disease in her feet and knees and degenerative disc disease in her spine. She was diabetic and had a history of gout. Prater stated that at her last job she experienced pain and fatigue “all the time.” None of her treating physicians indicated that she must alternate between sitting and standing. A vocational expert testified that a hypothetical individual with Prater's vocational background, education, and age, limited to sedentary work with restrictions on lifting, carrying, climbing, driving, and more, who could stand and walk no more than two hours of an eight-hour day and would need to change positions during the day but could remain in place for at least 30 minutes, whether sitting or standing, could not do any of Prater’s past jobs but could perform other jobs available in the national economy. The ALJ concluded that Prater was not disabled, finding that she had the residual functional capacity (RFC) to perform sedentary work with numerous restrictions; that her statements about the intensity, persistence, and limiting effects of her symptoms were “not entirely consistent” with the evidence; and that, although Prater was morbidly obese, “her physical examination was otherwise unremarkable.” The Appeals Council, the district court, and the Seventh Circuit upheld the decision. The sit/stand limitation in the RFC assessment is not too vague. The ALJ’s finding that she could sit and stand for 30 minutes at a time does not lack medical support; the ALJ did not improperly discredit her testimony that she could remain in position for only 20 minutes. View "Prater v. Saul" on Justia Law

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A jury convicted Dr. Chalhoub of defrauding health care benefit programs under 18 U.S.C. 1347. A Kentucky cardiologist, Chalhoub implanted permanent pacemakers in patients who did not need the devices or the tests that he ordered before and after surgery. On appeal, Chalhoub claimed that the district court repeatedly admitted evidence unduly prejudicial to him—and to which he could not effectively respond. The Sixth Circuit affirmed, acknowledging that “some of the government’s tactics here leave something to be desired.” Noting Chaloub’s failure to cross-examine, the court rejected a due process challenge to the admission of testimony by a doctor who claimed to have examined 20 of former Chaloub’s patients but could not name those patients. Chalhoub was not denied a right to be heard and the government did not base its case solely on allegations about those 20 victims. Chalhoub argued that he was severely prejudiced by testimony that he misbilled insurers for other unspecified procedures, but he did not seek clarification or additional information at trial. The court upheld the admission of testimony about Chaloub’s income and expenditures and testimony about his installation of a pacemaker in a former patient. View "United States v. Chalhoub" on Justia Law

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Plaintiff appealed the district court's decision affirming the denial of her application for supplemental security income. The Second Circuit vacated, holding that the ALJ erred in assuming that plaintiff's ability to complete a probationary period was irrelevant to her ability to perform significant numbers of jobs in the national economy. Accordingly, the court remanded the matter to the Commissioner for further development of the evidence. View "Sczepanski v. Saul" on Justia Law

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The Kreizenbecks sought compensation under the National Vaccine Injury Act, 42 U.S.C. 300aa-1–34, alleging that vaccinations administered to their son aggravated an underlying mitochondrial disorder and caused him to suffer immune system dysfunction and other medical problems. They submitted 1,500 pages of medical records, medical literature, Mrs. Kreizenbeck's affidavit, and reports from three medical experts. The government submitted reports from three experts. The Special Master determined that “a ruling on the papers was preferable to a hearing,” expressed “serious misgivings about the claims’ substantive validity,” and explained that if the parties proceeded to a hearing, he was unlikely to compensate the Kreizenbecks for costs. The Kreizenbecks chose to forgo a hearing but objected to a ruling on the record. The Master allowed the parties to submit final briefs, then determined that nothing in the record and expert reports suggested that the outcome would be different after a hearing. He found the government’s mitochondrial expert “reliable and persuasive,” the Kreizenbecks’ expert reports “conclusory or unsubstantiated” and Mrs. Kreizenbeck’s affidavit uncorroborated and inconsistent with the medical records. The Kreizenbecks did not dispute the substance of the claim denial but challenged the dismissal of their petition on the written record. The Claims Court affirmed, finding that the Master provided ample opportunity to support the claims with written material. The Federal Circuit affirmed, noting the Master’s broad discretion to rule on the record and rejecting a due process argument based on evaluating the credibility of the experts and Mrs. Kreizenbeck without live testimony or cross-examination. View "Kreizenbbeck v. Secretary of Health and Human Services" on Justia Law

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The Eighth Circuit affirmed the district court's denial of supplemental security income to claimant, who suffers from borderline intellectual functioning, learning delays, schizoaffective disorder, mood disorder, personality disorder, and an anxiety disorder. The court held that substantial evidence supported the ALJ's determination that claimant was not disabled within the meaning of the social security guidelines and listings regardless of which Section 12 mental disorder listing was considered. View "Cronin v. Saul" on Justia Law

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Changes to the Pennsylvania Human Services Code terminated a cash assistance program for certain low-income individuals administered by the Department of Human Services ("DHS"). Appellants, being aggrieved by the termination of Cash Assistance, filed in the Commonwealth Court’s original jurisdiction, a Class Action Petition for Review on behalf of themselves and others similarly situated, seeking a preliminary injunction to prevent that aspect of the law from taking effect until a final merits determination as to the constitutionality of the act as a whole could be reached. The Commonwealth Court denied the request. After review, the Pennsylvania Supreme Court concluded the Commonwealth Court did not abuse its discretion in determining Appellants failed to carry their burden with regard to the likelihood-of-success-on-the-merits aspect of the standard for preliminary injunctive relief. That being the case, the Supreme Court did not not address whether the court erred in finding that Appellants failed to demonstrate irreparable harm. View "Weeks v. DHS" on Justia Law