Justia Public Benefits Opinion Summaries

The case involves Bradley Rodriguez, who applied for disability benefits and supplemental security income, claiming a disability due to a traumatic brain injury, bipolar disorder, and depression. His application was denied by an Administrative Law Judge (ALJ) with the Social Security Administration (SSA). The Appeals Council also denied his request for review. Rodriguez then filed a federal lawsuit challenging the denial of benefits, raising several constitutional issues regarding the appointment of SSA ALJs, Appeals Council members, and the Commissioner of the SSA. He also argued that the ALJ’s decision was not supported by substantial evidence.The United States District Court for the Southern District of Florida granted summary judgment in favor of the Commissioner of the SSA. The court found that the ALJ was properly appointed, the Appeals Council members were not principal officers requiring presidential appointment and Senate confirmation, and the for-cause removal provision for the Commissioner was unconstitutional but severable. The court also held that Rodriguez was not entitled to a new hearing because he did not show that the unconstitutional removal provision caused him any harm. Additionally, the court determined that the ALJ’s decision was supported by substantial evidence.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The court held that the Commissioner had the statutory authority to appoint SSA ALJs and properly exercised that authority through ratification in July 2018. The Appeals Council members were deemed inferior officers, not principal officers, and thus did not require presidential appointment and Senate confirmation. The court also agreed that the for-cause removal provision for the Commissioner was unconstitutional but severable, and Rodriguez did not demonstrate entitlement to retrospective relief. Finally, the court found that the ALJ’s decision was supported by substantial evidence, including medical records and vocational expert testimony. View "Rodriguez v. Social Security Administration" on Justia Law

A mother sought child support from the father for their adult son, who has autism and receives government aid. The mother argued that the father, who earns a substantial income, should contribute to their son's support. The father contended that the son's receipt of government aid under the State Supplementary Program for Aged, Blind, and Disabled (SSP) relieved him of any financial responsibility under Family Code section 3910, which mandates parental support for adult children who are incapacitated and without sufficient means.The Superior Court of Los Angeles County ruled in favor of the father, interpreting Welfare and Institutions Code section 12350 to mean that the receipt of government aid barred the mother from seeking child support from the father. The court also limited the attorney’s fees awarded to the mother, reasoning that the case presented a narrow legal issue that did not justify extensive litigation costs.The California Court of Appeal, Second Appellate District, Division One, reversed the lower court's decision. The appellate court held that Welfare and Institutions Code section 12350 only prevents government entities from seeking reimbursement from relatives for the cost of aid provided to recipients. It does not bar a parent from seeking child support from the other parent under Family Code section 3910. The court emphasized that the legislative intent behind these statutes was to prevent the public from bearing the financial burden of supporting individuals who have relatives capable of providing support.The appellate court remanded the case for further proceedings to determine the appropriate amount of child support and to reconsider the attorney’s fees award in light of its ruling. The court clarified that the family court must now address whether the son is incapacitated from earning a living and without sufficient means, and if so, determine the appropriate support amount. View "Marriage of Cady & Gamick" on Justia Law

Plaintiff Michelle Rubin applied for Social Security Disability Insurance benefits in 2019, citing major depressive disorder as her disabling condition. An administrative law judge (ALJ) denied her claim, concluding that Rubin was not disabled under the Social Security Act. Rubin exhausted the administrative appeals process and subsequently challenged the final decision in the United States District Court for the Southern District of New York, which affirmed the denial of benefits.The ALJ found that Rubin had not engaged in substantial gainful activity since her alleged onset date and had a severe impairment of major depressive disorder. However, the ALJ determined that Rubin did not meet the criteria for a listed impairment and had the residual functional capacity (RFC) to perform a full range of work with certain nonexertional limitations. The ALJ partially discounted the opinion of Rubin’s treating psychiatrist, Dr. Paul, who had opined that Rubin met the criteria for a listed impairment and was unable to work full-time. The ALJ also found that Rubin could not perform her past relevant work but could perform other jobs existing in significant numbers in the national economy.The United States Court of Appeals for the Second Circuit reviewed the case and found that the ALJ’s decision was not supported by substantial evidence. The court noted that the ALJ had misinterpreted the medical and lay evidence, failing to appreciate the consistent narrative that supported Dr. Paul’s opinion. The court concluded that the ALJ erred in determining that Rubin did not meet the criteria for a listed impairment, particularly the paragraph C criteria of Listed Impairment 12.04. The court vacated the district court’s judgment and remanded the case to the agency for further proceedings, including a fuller consideration of the existing evidence and the results of a consultative examination. View "Rubin v. O'Malley" on Justia Law

Raymond Zaborowski, a U.S. Army veteran suffering from anxiety and PTSD, applied for Social Security disability benefits, claiming his conditions have prevented him from working since 2014. An administrative law judge (ALJ) denied his claim, stating that medical evidence indicated he could still perform light work.Zaborowski appealed to the United States District Court for the Eastern District of Pennsylvania, where he consented to jurisdiction by a magistrate judge. The magistrate judge upheld the ALJ's decision, leading Zaborowski to appeal further.The United States Court of Appeals for the Third Circuit reviewed the case. Zaborowski argued that the regulation requiring ALJs to explain their decisions violated the Social Security Act, that the ALJ failed to properly explain the supportability and consistency of medical opinions, and that the ALJ's findings were not supported by substantial evidence. The Third Circuit reviewed the legal issues de novo and the ALJ's factual findings for substantial evidence.The court held that the regulation complies with the statute, as it requires ALJs to explain the dispositive reasons for their decisions, specifically focusing on supportability and consistency. The court found that the ALJ adequately addressed these factors in her analysis, noting that the opinions of two psychologists were consistent with the record, while the treating psychiatrist's opinion was not. The court also found substantial evidence supporting the ALJ's decision, including the psychologists' opinions and evidence of Zaborowski's ability to live independently and assist his mother.The Third Circuit affirmed the decision, concluding that the ALJ's denial of benefits was supported by substantial evidence and that the regulation did not violate the Social Security Act. View "Zaborowski v. Commissioner Social Security" on Justia Law

M.G. and C.V., medically fragile children under New Mexico’s Medicaid program, sued the New Mexico Human Services Department (HSD) for failing to provide the private duty nursing (PDN) hours they are entitled to. They sought a preliminary injunction to compel HSD to take good faith steps to provide these hours. The district court granted the injunction, and HSD appealed.The United States District Court for the District of New Mexico found that M.G. and C.V. were consistently not receiving their required PDN hours, which placed them at risk of severe medical harm. The court concluded that M.G. and C.V. were likely to succeed on the merits of their Medicaid Act claims, which mandate the provision of PDN services. The court also found that the children would suffer irreparable harm without the injunction, that the balance of harms favored the plaintiffs, and that the injunction was in the public interest. The injunction required HSD to take specific steps, such as negotiating with managed care organizations and increasing monitoring of PDN hour shortfalls, to provide the necessary PDN hours.The United States Court of Appeals for the Tenth Circuit affirmed the district court’s decision. The appellate court held that M.G. and C.V. had standing to seek injunctive relief and that the district court did not err in its conclusions. The court found that the injunction was not impermissibly vague and that the Supreme Court’s decision in Armstrong v. Exceptional Child Center, Inc. did not preclude the issuance of the injunction. The Tenth Circuit concluded that the district court acted within its discretion in granting the preliminary injunction, given the likelihood of success on the merits, the risk of irreparable harm, the balance of harms, and the public interest. View "M.G. v. Armijo" on Justia Law

The case involves Alam & Sarker, LLC, a convenience store in New Bedford, Massachusetts, which was disqualified from participating in the federal Supplemental Nutrition Assistance Program (SNAP) by the United States Department of Agriculture's Food and Nutrition Service (FNS). The FNS's decision was based on data indicating irregular SNAP transactions at the store, including a high number of back-to-back transactions and unusually large purchases, which suggested trafficking in SNAP benefits.The United States District Court for the District of Massachusetts granted summary judgment in favor of the FNS. The court found that the transaction data provided sufficient evidence of trafficking and that the store failed to rebut this inference with significantly probative evidence. The Market's opposition, which included customer statements and inventory records, was deemed insufficient to create a genuine issue of material fact.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the FNS's reliance on SNAP transaction data was appropriate and that the Market did not provide adequate evidence to counter the strong inference of trafficking. The court also rejected the Market's procedural due process claim, noting that the de novo hearing in the district court cured any potential procedural deficiencies at the administrative level. The court concluded that the Market received all the process that was due and upheld the permanent disqualification from SNAP. View "Alam & Sarker, LLC v. US" on Justia Law

Harold Grimes, a coal miner for 34 years, developed black lung disease and later died of lung cancer in 2018. His widow, Susan Grimes, is eligible for survivor’s benefits under the Black Lung Benefits Act. The dispute centers on whether Apogee Coal Company, Grimes’s last employer, or the Black Lung Disability Trust Fund should pay these benefits. The Department of Labor’s administrative law judge (ALJ) and the Benefits Review Board assigned financial responsibility to Apogee, with Arch Resources Inc., Apogee’s former parent corporation, bearing the liability. Arch contested this, arguing that the Trust Fund should pay.The district director initially identified Apogee as a potentially liable operator and notified Arch as Apogee’s “Insurance Carrier.” Despite Apogee’s bankruptcy in 2015, the district director and ALJ concluded that Arch, as Apogee’s self-insuring parent, was responsible for the benefits. The ALJ’s decision was based on the premise that Arch’s self-insurance umbrella covered Apogee’s liabilities. The Benefits Review Board affirmed this decision, referencing its prior cases, including Howard v. Apogee Coal Co., which supported the Department’s theory of liability for self-insuring parents.The United States Court of Appeals for the Seventh Circuit reviewed the case and found no statutory or regulatory basis for holding Arch liable for Apogee’s obligations. The court emphasized that neither the ALJ nor the Board identified a specific provision in the Act or its regulations that justified this liability. The court vacated the Board’s decision and remanded the case with instructions to assign Mrs. Grimes’s benefits to the Black Lung Disability Trust Fund. The court noted that future cases might provide additional arguments for such liability, but in this instance, the Trust Fund must pay. View "Apogee Coal Co. v. Office of Workers' Compensation Programs" on Justia Law

In 2013, Johnny Ray Penegar, Jr. was diagnosed with mesothelioma, and Medicare partially covered his treatment costs. He filed a workers' compensation claim against his employer, UPS, and its insurer, Liberty Mutual. After his death, his wife, Carra Jane Penegar, continued the claim and added a death benefits claim. The North Carolina Industrial Commission (NCIC) ruled in her favor, ordering Liberty Mutual to cover all medical expenses related to the mesothelioma and reimburse any third parties, including Medicare. The NCIC's decision was affirmed by the North Carolina Court of Appeals and the Supreme Court of North Carolina denied further review. In 2020, Penegar and Liberty Mutual settled, with Liberty Mutual agreeing to pay $18,500 and to handle any Medicare liens.Penegar filed a class action lawsuit in the Western District of North Carolina under the Medicare Secondary Payer Act (MSP Act), alleging that Liberty Mutual failed to reimburse Medicare, leading to a collection letter from the Centers for Medicare and Medicaid Services (CMS) demanding $18,500. Liberty Mutual moved to dismiss, arguing Penegar lacked standing and that the settlement precluded her claims. The district court agreed, finding Penegar lacked standing and dismissed the case.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The court held that Penegar did not suffer a cognizable injury in fact at the time she filed the lawsuit. The NCIC had ordered Liberty Mutual to reimburse Medicare directly, not Penegar, distinguishing her case from Netro v. Greater Baltimore Medical Center, Inc. Additionally, the CMS letter only posed a risk of future harm, which is insufficient for standing in a damages suit. Finally, any out-of-pocket expenses Penegar incurred were already compensated by Liberty Mutual before she filed the lawsuit, negating her claim of monetary injury. View "Penegar v. Liberty Mutual Insurance Co." on Justia Law

Christina Barrera, the office manager at PowerMed, was involved in a scheme to help unqualified individuals, mainly employees of AB InBev, fraudulently obtain disability benefits from the Social Security Administration (SSA) and private insurers. Patients paid PowerMed $21,600 for a "disability package" that included unnecessary medical tests and assistance in fraudulently applying for disability benefits. Barrera explained the scheme to patients, helped them complete paperwork, and coached them on how to appear disabled. An undercover officer's investigation led to Barrera's indictment and subsequent trial, where a jury found her guilty of conspiracy to defraud the SSA but acquitted her of health care fraud and theft of government funds.The United States District Court for the Eastern District of Missouri sentenced Barrera, ordering her to pay restitution to the SSA and private insurers. The presentence investigation report (PSR) recommended $339,407.80 in restitution to the SSA, but the Government argued for additional restitution to private insurers, totaling $203,907.62. The district court adopted the Government's figures, ordering Barrera to pay a total of $543,315.42 in restitution. After Barrera's sentencing, her co-conspirator Clarissa Pogue was sentenced but was not required to pay restitution to private insurers, leading Barrera to appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Barrera's criminal conduct included defrauding private insurers as part of the scheme to defraud the SSA, affirming the district court's decision to order restitution to private insurers. However, the court found errors in the calculation of restitution amounts for Prudential and MetLife, vacating those portions and remanding for further proceedings. The court rejected Barrera's argument regarding sentencing disparities with Pogue, emphasizing that the statutory direction to avoid unwarranted sentence disparities refers to national disparities, not differences among co-conspirators. The judgment was affirmed in part, vacated in part, and remanded. View "United States v. Barrera" on Justia Law

Nancy Vargas, a bus driver for the Santa Barbara Metropolitan Transit District, injured her foot at work in March 2018. She settled her workers' compensation claim with the district in December 2020, agreeing that the injury caused a 26 percent permanent disability. Vargas also applied for subsequent injury benefits from the Subsequent Injuries Benefits Trust Fund (Fund), listing pre-existing disabilities and disclosing that she was receiving Social Security Disability Insurance (SSDI) payments.The Workers’ Compensation Appeals Board (Board) joined the Fund as a defendant in Vargas’s case. The Fund acknowledged Vargas’s eligibility for benefits but sought a credit for a portion of her SSDI payments, arguing that these payments were for her pre-existing disabilities. The workers’ compensation judge (WCJ) found that the Fund had not proven its entitlement to the credit. The Board upheld this decision, stating that the Fund failed to show that the SSDI payments were awarded for Vargas’s pre-existing disabilities.The California Court of Appeal, Second Appellate District, reviewed the case. The court affirmed the Board’s decision, holding that the Fund bears the burden of proving its entitlement to a credit for SSDI payments under Labor Code section 4753. The court found that the Fund did not provide sufficient evidence to establish that Vargas’s SSDI payments were for her pre-existing disabilities. The court emphasized that the Fund must prove the extent to which SSDI payments are attributable to pre-existing disabilities to reduce subsequent injury benefits. The court also noted that the Fund had ample opportunity to gather evidence but failed to do so. The Board’s order denying the Fund’s petition for reconsideration was affirmed. View "Subsequent Injuries Benefits Trust Fund v. Workers' Compensation Appeals Board" on Justia Law