Justia Public Benefits Opinion Summaries

Several individuals applied for federal Supplemental Security Income (SSI) but experienced delays in receiving a determination of eligibility. While they waited, New York State provided them with interim public assistance through the Safety Net Assistance (SNA) program, which required participation in work experience programs (WEPs). The value of the assistance was tied to the minimum wage for the hours worked. Once petitioners were deemed eligible for SSI, the Social Security Administration issued retroactive SSI payments covering the period of delay, and New York was reimbursed from these payments for the interim assistance it had provided. Petitioners received the remainder of the retroactive SSI after reimbursement.Following an unsuccessful administrative challenge, petitioners commenced a combined CPLR article 78 proceeding and putative class action, contending that New York’s practice of recouping the full value of SNA from their retroactive SSI awards violated the Fair Labor Standards Act (FLSA) by effectively creating an unlawful “kick-back” of minimum wage earned through WEP participation. Supreme Court ruled in petitioners’ favor, holding that the reimbursement process was subject to the FLSA and must reflect the value of WEP labor. The Appellate Division, Third Department, unanimously reversed, determining that petitioners were not deprived of minimum wage compensation because they had already received the value of their work in interim assistance and that reimbursement merely prevented duplicate payments for the same period.The New York Court of Appeals affirmed the Appellate Division’s order. It held that reimbursement to New York from petitioners’ retroactive SSI awards for interim assistance, conditioned on WEP participation, does not violate the FLSA. The Court concluded that petitioners received all compensation to which they were entitled under federal law, including the minimum wage, and that federal law expressly authorizes such reimbursement to prevent windfalls. The holding applies regardless of whether interim assistance is conditioned on work activities. View "Andersen v Hein" on Justia Law

A Medicaid recipient in her late 80s, suffering from serious health conditions, applied in 2019 for 24-hour at-home personal care services through New York’s Medicaid program. The state, which provides varying levels of in-home care to eligible Medicaid recipients, partners with private managed long-term care plans (MLTCPs) to assess needs and offer care plans. The plaintiff was initially offered only eight hours of daily care by all MLTCPs she applied to, though she believed she required around-the-clock assistance. Under New York’s regulations, individuals cannot immediately appeal the initial level of care offered; they must first enroll in the plan, request an increase, and only appeal if that request is denied. The plaintiff followed this process and ultimately received 24-hour care after subsequent assessments, but with a delay and a gap in retroactive reimbursement for services.The United States District Court for the Southern District of New York granted summary judgment to the defendants—the State's Health Commissioner and the MLTCP—holding that the plaintiff did not have a cognizable property interest in a particular level of care, and therefore no due process rights were implicated. The court also denied class certification. The plaintiff appealed these decisions.The United States Court of Appeals for the Second Circuit reviewed the case de novo. The Second Circuit disagreed with the District Court’s conclusion regarding the existence of a property interest. It held that New York’s laws, regulations, and practices substantially restrict discretion in determining eligibility for 24-hour personal care services, thereby creating a property interest for qualifying Medicaid recipients and triggering due process protections. However, the court determined that New York’s current appeals procedures, though delayed, are constitutionally adequate because the delay is modest, expedited procedures exist for urgent cases, and the overall private interests at stake are sufficiently protected. On this alternative ground, the Second Circuit affirmed the District Court’s grant of summary judgment to the defendants. View "Bellin v. McDonald" on Justia Law

A former court reporter who worked for nearly four decades for a California county discovered, as she approached retirement, that the county had failed to enroll her in the state retirement system (CalPERS) for several years early in her employment. Upon learning this, she attempted to secure a complete employment record from the county, which CalPERS required to adjust her retirement benefits. The county failed to provide complete records, reportedly due to records being lost or destroyed, and provided only incomplete information to CalPERS. This left her unable to purchase prior service credit or receive full retirement benefits, causing her financial harm and forcing her to delay retirement.After filing a claim with the county and receiving no response, the plaintiff brought multiple causes of action in the Humboldt County Superior Court, including alleged violations of statutory duties and negligence against the county and individual employees. The trial court sustained the defendants’ demurrers, dismissing all statutory claims without leave to amend and granting leave to amend only the negligence claim. When the plaintiff submitted an amended complaint limited to negligence, the trial court again sustained the demurrer without leave to amend, finding no statutory duty supported the claim.The California Court of Appeal, First Appellate District, Division One, reviewed the case. It held that the plaintiff had stated valid causes of action against the county for violation of mandatory statutory duties to maintain personnel records and to enroll eligible employees in CalPERS under Government Code section 815.6. The court also held, in an unpublished portion, that the plaintiff stated a viable negligence claim against the individual defendants, with the county potentially vicariously liable. The appellate court reversed the trial court’s dismissal of these claims and remanded for further proceedings. View "Gibbs v. County of Humboldt" on Justia Law

A per diem judge had been credited with retirement service by the Employee Retirement System (ERS) for years under a 1990 memorandum that set eligibility criteria. In 2017, the ERS discovered that the Judiciary had not updated personnel forms as the memorandum appeared to require. Without notice or a hearing, ERS issued a new memorandum rescinding the 1990 policy and retroactively stripped the judge’s retirement credits for service after October 1, 2017. The ERS did not follow rulemaking procedures required by Hawaii’s Administrative Procedure Act.The judge administratively challenged the ERS decision. A hearing officer partially sided with her, but the Board of Trustees of the ERS overruled that recommendation and dismissed all claims. The judge appealed to the Circuit Court of the First Circuit, which reversed the ERS Board, finding that both the 1990 and 2017 memoranda were rules under HRS § 91-1 and invalid because they had not been properly promulgated. On appeal, the Intermediate Court of Appeals (ICA) reversed, agreeing that the memoranda were improperly issued but holding that the circuit court’s reasoning did not support the relief granted.The Supreme Court of the State of Hawai‘i reviewed the case. It held that both the 1990 and 2017 memoranda were rules affecting private rights, not mere internal management or intra-agency communications, and thus subject to statutory rulemaking procedures. The 2017 memorandum and its implementing letter were void as to the judge because they were not lawfully adopted and she had timely challenged them. However, because no timely challenge was made to the 1990 memorandum, it remained valid and controlled her eligibility. The Supreme Court vacated the ICA’s decision, reinstated the circuit court’s judgment, and ordered the ERS to credit the judge for eligible service. View "Martel v. Employee Retirement System" on Justia Law

After separating from his employment with Walman Optical, the claimant created an optical consultation business. He designed a website, spent nearly $3,000 on advertising, and reported a net loss on his tax filings, but had not performed any services for clients or received earnings from the business. Shortly after these activities, he applied for unemployment compensation benefits.The Altoona UC Service Center determined that the claimant was ineligible for benefits, reasoning that his creation of a new business rendered him self-employed. Following a hearing, a referee affirmed this denial, and the Unemployment Compensation Board of Review adopted the referee’s findings and upheld the decision. Both the referee and the Board relied on the “positive steps” test, concluding that the claimant’s actions toward establishing a business meant he was customarily engaged in self-employment, even though he had not performed any services or received any wages.The claimant appealed to the Commonwealth Court of Pennsylvania, arguing that the “positive steps” test conflicted with the statutory requirements for self-employment. The Commonwealth Court, in a divided en banc opinion, affirmed the denial of benefits, holding that the positive steps test remained applicable in the context of a stand-alone business enterprise and that actual remuneration or performance of services was not necessary for a finding of self-employment.The Supreme Court of Pennsylvania reviewed the case and reversed the Commonwealth Court’s order. The Court held that Section 4(l)(2)(B) of the Unemployment Compensation Law sets forth the test for determining self-employment and that the positive steps test is contrary to the statute’s plain language. The Court concluded that self-employment requires the actual performance of services for wages and that merely taking steps to establish a business, without performing such services, does not disqualify a claimant from receiving benefits. View "Precht v. UCBR" on Justia Law

Arthur Miles was sentenced to a total of 300 months’ imprisonment following two separate federal convictions. After his first sentencing in October 2022, Miles was housed at the Marion County Jail in Indiana for fifteen months—some of this time was before and some after his second federal sentencing. During his time at the county jail, Miles worked as an orderly. He later argued that under the First Step Act of 2018 (“FSA”), he was entitled to earn time credits for this work, which could reduce his sentence, because his federal sentence had commenced and the work was equivalent to an evidence-based recidivism reduction (“EBRR”) program.The United States District Court for the District of Massachusetts reviewed Miles’s habeas petition after a magistrate judge recommended denying the Bureau of Prisons’ (BOP) motion to dismiss. The magistrate judge found that BOP regulations preventing prisoners from earning FSA credits until they arrived at a federal facility conflicted with the FSA’s language. The district court, however, rejected this recommendation and dismissed Miles’s petition, holding that the BOP’s rules did not violate the FSA.The United States Court of Appeals for the First Circuit held that the BOP’s regulation, which delayed the accrual of FSA time credits until a prisoner’s arrival at a federal facility, was invalid because it conflicted with the statutory definition of when a sentence commences. The court further held that a risk and needs assessment is not a prerequisite for earning FSA credits, and that prisoners may earn credits for qualifying programming—such as work as an orderly—performed after sentencing even while housed in non-federal facilities. The court vacated the dismissal of Miles’s habeas petition and remanded for further proceedings to determine his entitlement to credits for his time at the county jail. View "Miles v. Bowers" on Justia Law

The petitioner, a former Legal Administrative Specialist at the Office of Personnel Management (OPM), was diagnosed with major depressive disorder, generalized anxiety disorder, and insomnia. Her treating psychiatrist determined she was unable to work, and OPM subsequently removed her from federal service, citing her medical inability to perform essential job functions. The removal decision relied on medical documentation from her psychiatrist, which described her symptoms and limitations. Following her removal, the petitioner applied for disability retirement benefits through OPM, submitting the same medical documentation.OPM denied the disability retirement application, stating that while it acknowledged her diagnoses and symptoms, there was insufficient “objective” medical evidence to demonstrate the degree of her impairment and her inability to work. On reconsideration, OPM repeated that the documentation lacked details such as test results, psychotherapy notes, and treatment records. The petitioner appealed to the Merit Systems Protection Board (the Board), where OPM maintained its position that her evidence was inadequate. The Board’s administrative judge found that OPM had rebutted the presumption of disability—established when an employee is removed for medical inability—by asserting a lack of objective medical evidence. The Board weighed the evidence and affirmed OPM’s denial, making this its final decision.On review, the United States Court of Appeals for the Federal Circuit addressed whether OPM and the Board could overcome the presumption of disability (as set out in Bruner v. Office of Personnel Management) simply by asserting the absence of objective medical evidence. The court held that such an assertion alone is insufficient to rebut the presumption of disability. Because the Board relied solely on this rationale, the court concluded the presumption was not rebutted, reversed the Board’s final order, and found the petitioner entitled to disability retirement benefits. View "Garland v. Office of Personnel Management" on Justia Law

A miner who worked in West Virginia coal mines for nearly four decades applied for benefits under the Black Lung Benefits Act after retiring in 2015. From mid-2012 through December 2014, he worked for Rhino Energy, LLC as a subcontractor in mines owned by Wildcat Energy, LLC. When Rhino’s subcontract ended, he joined Wildcat’s payroll and continued working at Wildcat until his retirement in October 2015. The dispute centers on which employer—Rhino or Wildcat—should be responsible for paying his black lung benefits.After the miner filed his claim, the district director of the Office of Workers’ Compensation Programs designated Rhino as the responsible operator, finding that Wildcat had not employed the miner for the full year required by regulations and thus was not a potentially liable operator. The district director did not address Wildcat’s financial capacity, nor did he issue a Coverage Statement regarding Wildcat’s insurance status. Rhino contested its designation, arguing Wildcat should be responsible, including as a successor operator, but the district director and subsequently the Administrative Law Judge (ALJ) reaffirmed Rhino’s liability, focusing on the duration of Wildcat’s employment. The Benefits Review Board upheld the ALJ’s decision, agreeing that Wildcat had not employed the miner for a year and noting Rhino had not demonstrated Wildcat’s financial capability.The United States Court of Appeals for the Fourth Circuit reviewed the Board’s order. It held that under the correct interpretation of the regulations, Wildcat had employed the miner for the requisite year based on working days, and because the district director did not issue a Coverage Statement, Wildcat was presumed financially capable of paying benefits. The court determined Wildcat should have been designated as the responsible operator, but because regulations prohibit imposing liability on another operator at this stage, it vacated the Board’s order and remanded with instructions for the Black Lung Disability Trust Fund to pay the miner’s benefits. View "Rhino Energy, LLC v. DOWCP" on Justia Law

Michael Lincoln applied for disability insurance benefits and supplemental security income, alleging that his ability to work was limited due to conditions including prostate cancer, for which he received treatment beginning in late 2019. His treatment concluded in mid-2020, and his cancer entered remission. Lincoln continued to experience symptoms such as fatigue and reported using a cane at times, but also engaged in various daily activities. He claimed an inability to work beginning in October 2019.An administrative law judge (ALJ) held a hearing in May 2022 and, in August 2022, concluded that Lincoln was not disabled. The ALJ determined that Lincoln had the residual functional capacity to perform “light work” with certain postural limitations, and specifically found that Lincoln could perform his past work as a school bus driver. In reaching this conclusion, the ALJ found that Lincoln’s subjective complaints regarding fatigue and cane use were not entirely consistent with the medical evidence and daily activities. The ALJ also found the opinions of state agency medical consultants more persuasive than that of Lincoln’s treating nurse practitioner. The Appeals Council denied further review, making the ALJ’s decision final. The United States District Court for the Central District of Illinois affirmed the ALJ’s decision.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the ALJ’s findings, applying a deferential “substantial evidence” standard. The court held that substantial evidence supported the ALJ’s determination regarding Lincoln’s residual functional capacity, including the findings related to Lincoln’s fatigue, cane use, and the persuasiveness of medical opinions. Accordingly, the court affirmed the judgment of the district court, upholding the denial of benefits. View "Lincoln v. Bisignano" on Justia Law

A federal prisoner was sentenced in December 2020 and, due to pending charges in another jurisdiction, was held at a detention center in Rhode Island rather than being promptly transferred to his designated Bureau of Prisons (BOP) facility in South Carolina. During this period of post-sentencing detention, the prisoner claims to have participated in programs under the First Step Act (FSA), thereby accruing approximately 150 days of time credits, which could reduce his time in custody. However, the BOP did not recognize these credits because he had not undergone a formal risk and needs assessment—the BOP’s prerequisite for awarding such credits—until his eventual arrival at the designated facility in March 2022.After exhausting administrative remedies, the prisoner filed a pro se habeas petition in the United States District Court for the District of South Carolina, seeking recognition of his alleged FSA credits. The magistrate judge, without briefing or discovery, recommended dismissal. The district court adopted this recommendation, concluding that the BOP’s regulation reasonably required an initial assessment before credits could be earned, and applied Chevron deference to uphold the agency's interpretation. The district court also found no evidence the prisoner had “successfully participated” in qualifying programs before arrival at the BOP facility and dismissed the petition without prejudice, refusing to require a government response.On appeal, the United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment and remanded. The Fourth Circuit held that the case was not moot, as the prisoner could still benefit from the FSA credits if his risk status changed or a warden approved his release. The court further held that, in light of the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo, which overturned Chevron deference, the district court must independently determine whether the BOP’s interpretation of “successful participation” aligns with the best reading of the statute. View "Benson v. Warden FCI Edgefield" on Justia Law