Justia Public Benefits Opinion Summaries

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While plaintiffs sought judicial review in federal district court of their denial of Social Security disability benefits, the Supreme Court issued its opinion in Lucia v. Securities and Exchange Commission, 138 S. Ct. 2044 (2018), which elucidated a possible constitutional objection to administrative proceedings pursuant to the Appointments Clause. At issue in this appeal is whether plaintiffs may raise an Appointments Clause challenge in federal court that they did not preserve before the agency.The Fourth Circuit held that claimants for Social Security disability benefits do not forfeit Appointments Clause challenges by failing to raise them during their administrative proceedings. Balancing the individual and institutional interests at play, including considering the nature of the claim presented and the characteristics of the ALJ proceedings, the court declined to impose an exhaustion requirement. Therefore, the court affirmed the judgments of the district courts remanding these cases for new administrative hearings before different, constitutionally appointed ALJs. View "Probst v. Saul" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court entering judgment in favor of Yankton County on Sacred Heart Health Service Inc.'s (Hospital) declaratory judgment against the County, holding that circuit court did not err in holding S.D. Codified Laws chapter 28-13 is the proper mechanism for the Hospital to obtain reimbursement from the County for medical costs associated with the twenty-three patients in the involuntary commitment process.The Hospital brought a declaratory judgment action against the County seeking a declaration as to the County's liability and reimbursement for charges for the medical care and treatment of patients subject to an emergency hold under S.D. Codified Laws chapter 27A-10. The circuit court first entered a memorandum decision in favor of the Hospital, but after granting the County's motion to reconsider issued a second memorandum decision and corresponding judgment in favor of the County. The Supreme Court affirmed, holding (1) the circuit court did not err in granting the County's motion for summary judgment; (2) the Hospital did not have a claim in quantum merit for reimbursement from the County; and (3) the circuit court did not err in granting the County's motion to reconsider. View "Sacred Heart Health Services v. Yankton County" on Justia Law

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The Court of Appeal held that a DSS regulation, Manual of Policies and Procedures (MPP) section 63-603, which addresses replacement issuances of benefits (formerly known as food stamps) under California's CalFresh program, was lawfully adopted and does not conflict with any state or federal statute, and that its plain language requires county welfare departments (CWDs) to replace CalFresh benefits lost through electronic theft (provided a replacement request is made within 10 days of the loss). In this case, MPP 63-603 was within the scope of authority conferred by enabling statutes, and Welfare and Institutions Code section 10072 does not affect the court's analysis. Therefore, the trial court erred by denying plaintiffs' petition for writ of mandate. The court reversed the trail court's judgment and remanded for the trial court to grant the petition. View "Ortega v. Johnson" on Justia Law

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The Ninth Circuit vacated the district court's judgment affirming the denial of claimant's application for social security disability benefits. In Bellamy v. Secretary of Health and Human Services, 755 F.2d 1380 (9th Cir. 1985), the panel held that a claimant's prior disability determination entitled claimant to a presumption of continuing disability. The SSA interpreted then-recent amendments to the Social Security Act as foreclosing any presumption of continuing disability.Deferring to the SSA's intervening interpretation of the Social Security Act, which is a reasonable one, the panel held that there is no presumption of continuing disability under the Act. Consequently, the ALJ did not err in evaluating, without any such presumption, the SSA's determination that claimant is no longer disabled. However, the ALJ did err in failing to articulate sufficient reasons for refusing to credit plaintiff's testimony about the severity of her medical condition. The panel remanded for further proceedings. View "Lambert v. Saul" on Justia Law

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The Randolph-Sheppard Act, 20 U.S.C. 107(a), provides economic opportunities by granting blind persons priority to operate vending facilities at certain government properties. When a blind vendor, Belsha, was awarded certain vending operations in Racine County, Wisconsin, a different blind vendor, Taylor, became unhappy and challenged the award. The Act is administered by state licensing agencies; Taylor’s challenge traveled first through Wisconsin’s regulatory process. Although Taylor achieved some success through the Wisconsin Division of Vocational Rehabilitation, she commenced federal administrative proceedings with the Secretary of Education. An arbitration panel awarded Taylor money damages and a permanent vending machine services contract for a site in Racine.The district court vacated the arbitration decision, ruling that there were no material deficiencies in the choice of Belsha for the Racine site, that the arbitration panel’s key factual findings were not supported by substantial evidence, and the arbitration panel’s ultimate conclusion was arbitrary and capricious. The Seventh Circuit affirmed. The arbitration panel mistakenly substituted the APA standard of review for the burden of proof of a disappointed vendor under the Act. View "Wisconsin Department of Workforce Development v. Taylor" on Justia Law

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The Supreme Judicial Court affirmed in part and vacated in part the judgment of the superior court affirming the decision of the Commissioner of the Department of Health and Human Services (Department) accepting the recommendation of an administrative presiding officer that the Department correctly established and maintained a recoupment claim for $116,852 against Appellant, an oral surgeon, holding that remand was required as to one aspect of the Department's decision.Appellant was a MaineCare provider whose practice was based in Auburn. After Appellant retired, the Department issued a notice of violation, alleging that Appellant had been overpaid. After an administrative hearing, the Department reduced its claim to $116,852. The presiding officer upheld the Department's recoupment claim. The Commissioner adopted the presiding officer's recommended decision in full. The Supreme Judicial Court reversed in part and remanded the case, holding (1) because the Department failed to explain its decision imposing the maximum allowable penalties for Appellant's failure properly to document time spent with patients following his administration of anesthesia, the Court was unable to determine whether the Department properly exercised its discretion; and (2) Appellant was not entitled to relief on his remaining allegations of error. View "Palian v. Department of Health and Human Services" on Justia Law

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The Ninth Circuit affirmed the denial of social security disability benefits to claimant under Title II of the Social Security Act. The panel held that the ALJ did not err in discounting claimant's testimony where substantial evidence supported the ALJ's finding that claimant had engaged in drug-seeking behavior; the ALJ did not err in weighing the medical-opinion evidence; and the ALJ did not err in excluding pain disorder as a severe impairment. View "Coleman v. Saul" on Justia Law

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Community Mental Health modified the methodology through which it allocated funding to individuals with disabilities receiving community living support services under a Medicaid waiver received by Michigan. Individuals receiving those services, together Advocacy, challenged that methodology as violating the Medicaid Act, 42 U.S.C. 1396a(a)(8), (a)(10)(A), (a)(10)(B), 1396n(c)(2)(A) and (C); Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12132; section 504 of the Rehabilitation Act, 29 U.S.C. 794; the Michigan Mental Health Code; and the terms of Michigan’s Medicaid Habilitation Supports Waiver and the contracts implementing it. The district court dismissed the claims in full.The Sixth Circuit reversed, first holding that the plaintiffs have standing, that the defendants are not entitled to Eleventh Amendment immunity, that the plaintiffs were not required to exhaust their administrative remedies provided by the state under the Medicaid Act, and that the plaintiffs have a private right of action under sections 1396a(a)(8) and (a)(10). The plaintiffs’ allegations suffice to state plausible claims that they are being denied sufficient necessary medical services; that feasible alternatives that provide them a meaningful choice between institutionalized and at-home or community-based care exist and are not being ensured; and that they face a serious risk of institutionalization. View "Waskul v. Washtenaw County Community Mental Health" on Justia Law

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The district court affirmed the North Dakota Department of Human Service’s determination that Harold Ring was ineligible for Medicaid. When these proceedings began, Ring was ninety-six years old and living in the Good Samaritan Home in Mohall. An application for Medicaid was submitted on his behalf in April 2018. It was denied due to disqualifying transfers. Ring’s daughter, Nancy Ring, filed a second Medicaid application on Ring’s behalf in November 2018. The November application was also denied because Ring’s “client share (recipient liability) is more than the medical expenses.” Ring died after the Department issued its decision but before the district court affirmed. No party was substituted on Ring’s behalf for purposes of the district court proceedings. In 2020, Ring's attorney filed a notice of appeal to the North Dakota Supreme Court, claiming the Department’s imposition of a penalty period due to disqualifying transfers was inappropriate because Ring was a vulnerable adult who was financially exploited. On May 1, 2020, the Good Samaritan Society and the Department stipulated to dismissal of the probate petition because “a Special Administrator is not needed at this time.” The court dismissed the petition on May 5, 2020. The Supreme Court determined that essential issues remained unresolved in this matter: since neither side filed a notice of death or moved to substitute a party, the district court did not determine whether this action survived Ring's death, and if it did, whether a proper successor was available for substitution. The matter was remanded for these findings and substitution. View "Ring v. NDDHS" on Justia Law

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Veterans sought certification for the class of veterans whose disability claims had not been resolved by the Board of Veterans Appeals within one year of the filing of a Notice of Disagreement (NOD), requesting judicial action to compel the Secretary of Veterans Affairs to decide all pending appeals within one year of receipt of a timely NOD. The Veterans Court requested that they separate or limit the requested class action into issues that meet the Federal Rule of Civil Procedure 23(b)(2) “commonality” standard. The veterans declined, stating that “systemic delay” exists in the VA claims system, and broad judicial remedy is required.The Veterans Court denied the requested class certification. While the case was pending, the Veterans Appeals Improvement and Modernization Act of 2017, 131 Stat. 1105 purportedly improved processing times by allowing claimants to choose: higher-level review, a supplemental claim, board review with a hearing and opportunity to submit additional evidence, board review without a hearing, but with an opportunity to submit additional evidence, or board review without a hearing or additional evidence, based on their priorities on appeal.The Federal Circuit affirmed the denial of class certification, citing the lack of proof of commonality. When Congress has crafted a comprehensive remedial structure, that structure warrants evaluation in practice before judicial intervention is contemplated. View "Monk v. Wilkie" on Justia Law