Justia Public Benefits Opinion Summaries

A group of plaintiffs filed suit against the Secretary of the Alabama Department of Workforce, alleging that the Department’s handling of their unemployment benefits applications during the COVID-19 pandemic was unlawful. The plaintiffs claimed that the Department’s policies and practices resulted in unreasonable delays and inadequate communication, violating both the Social Security Act and the Due Process Clause of the Fourteenth Amendment. They sought various forms of injunctive relief, including orders requiring prompt decisions on applications, timely payment of approved claims, and clearer communication with claimants.The Montgomery Circuit Court granted the Secretary’s motion to dismiss the case, without specifying the grounds for dismissal. The plaintiffs’ motion to alter or vacate the judgment was denied. On appeal, the Supreme Court of Alabama affirmed the dismissal, holding that the plaintiffs had not exhausted their administrative remedies and that the courts lacked the power to address the merits of their claims. The plaintiffs then sought review by the United States Supreme Court.The United States Supreme Court reversed the Alabama Supreme Court’s judgment, holding that the state’s administrative exhaustion requirement could not be used to bar federal due process claims under 42 U.S.C. § 1983 for alleged delays in processing unemployment benefits. On remand, the Supreme Court of Alabama considered supplemental briefing on whether the case had become moot, as the Secretary asserted that all plaintiffs had either been paid or received final denials. The plaintiffs disputed this and requested a remand for a factual determination. The Supreme Court of Alabama remanded the case to the Montgomery Circuit Court to determine whether the case is now moot, instructing the lower court to resolve the factual dispute regarding mootness. View "Johnson v. Reed" on Justia Law

A plaintiff who lost his job during the COVID-19 pandemic applied for and received regular unemployment benefits from the Washington State Employment Security Department (ESD). After exhausting those benefits, he applied for and received additional benefits under the federally funded Pandemic Emergency Unemployment Compensation (PEUC) program, created by the CARES Act. Following an audit, ESD redetermined his eligibility, reduced his weekly benefit, and assessed overpayments, sending him multiple, confusing notices with inconsistent information and deadlines. While the plaintiff appealed, ESD began offsetting his ongoing PEUC benefits to recover the alleged overpayments.An administrative law judge later found that ESD’s notices failed to provide adequate explanation or legal basis for the benefit reductions and overpayment assessments, and ordered ESD to issue a new redetermination. ESD reimbursed the plaintiff for the offset amounts, but its system continued to show a balance owed. The plaintiff, on behalf of himself and similarly situated individuals, filed a putative class action in the United States District Court for the Western District of Washington, alleging deprivation of property without due process under the Fourteenth Amendment and the Social Security Act. The district court held that while the plaintiff had a property interest in regular unemployment benefits, he did not have a constitutionally protected property interest in PEUC benefits, because state participation in the PEUC program was voluntary and could be terminated at any time.On interlocutory appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s ruling. The Ninth Circuit held that the CARES Act’s PEUC program, once a state opted in, created a constitutionally protected property interest in PEUC benefits for eligible individuals. The Act’s mandatory language and objective eligibility criteria significantly constrained state discretion, giving rise to legitimate claims of entitlement. The case was remanded for further proceedings. View "STERLING V. FEEK" on Justia Law

Two children, E.R. and G.S., have severe, complex medical conditions that require constant, skilled care. Their mothers, who are their primary caregivers and sole financial supporters, have been trained by medical professionals to provide the necessary care at home. For years, Indiana’s Medicaid program reimbursed these mothers for providing “attendant care services” under a waiver program designed to keep individuals out of institutions. In July 2024, the Indiana Family and Social Services Administration (FSSA) implemented a policy change that would make parents ineligible to be paid providers of attendant care for their children, threatening to force E.R. and G.S. into institutional care due to the lack of available in-home nurses.The Indiana Protection and Advocacy Services Commission, along with E.R. and G.S., sued to block the policy change and require FSSA to secure in-home nursing. The United States District Court for the Southern District of Indiana initially granted a preliminary injunction requiring FSSA to take steps to obtain in-home nurses and to pay the mothers for a different, lower-paid service. After further proceedings, the court modified its order, ultimately requiring FSSA to pay the mothers for attendant care at the previous rate until in-home nursing could be secured.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s October 1 injunction. The court held that the plaintiffs are likely to succeed on their claims under the Americans with Disabilities Act’s integration mandate, which requires states to provide services in the most integrated setting appropriate. The court found that prohibiting the mothers from providing paid attendant care placed the children at serious risk of institutionalization and that FSSA had not shown that allowing such care would fundamentally alter the Medicaid program or violate federal law. The case was remanded for further proceedings. View "Indiana Protection and Advocacy Services Comm'n v Indiana Family and Social Services Administration" on Justia Law

In 1994, Kenneth Hayes was murdered in Wayne County, Michigan. Larry Smith was convicted of first-degree murder and a firearm charge, largely based on the testimony of Edward Allen, a jailhouse informant who claimed Smith confessed to the crime. Smith’s conviction was affirmed on direct appeal, and his subsequent state and federal habeas petitions were unsuccessful. Years later, the Wayne County Prosecutor’s Conviction Integrity Unit investigated and found evidence suggesting Allen’s testimony may have been fabricated as part of a broader scheme involving police and prosecutors eliciting false testimony from informants. Smith’s conviction was vacated in 2021, and he was released from prison.After his release, Smith obtained compensation from the State of Michigan under the Wrongful Imprisonment Compensation Act (WICA), settling for $850,000 and signing a release of claims against the State. He then filed a federal lawsuit against Wayne County and prosecutor Robert Donaldson, alleging constitutional violations under 42 U.S.C. § 1983 and a Monell claim against the County for policies encouraging false testimony. The United States District Court for the Eastern District of Michigan granted summary judgment to both defendants, finding Donaldson was protected by absolute prosecutorial immunity and that Smith’s settlement under WICA released his claims against Wayne County.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. It held that Donaldson was entitled to absolute prosecutorial immunity because his conduct—preparing a witness for trial—was within the scope of his advocacy role, not investigatory. The court also held that Smith’s acceptance of the WICA settlement released all claims against Wayne County, including federal claims, as a matter of law. The Sixth Circuit affirmed the district court’s grant of summary judgment to both defendants. View "Smith v. Wayne County" on Justia Law

A group of foster children challenged the Office of Children’s Services (OCS) for using their federal Social Security benefits to reimburse itself for foster care costs. The children claimed this practice violated their due process and equal protection rights under the Alaska Constitution and sought restitution. The Superior Court of Alaska found a due process violation and ordered OCS to notify foster children about its practice regarding Social Security benefits. However, the court rejected the equal protection and restitution claims, deeming them preempted by federal law.The Superior Court held that OCS violated due process by not informing foster children about their Social Security benefits and the potential financial advantages of having a private representative payee. The court ordered OCS to provide notices explaining the concept of a representative payee, the consequences of OCS being the payee, and the possibility of proposing an alternative payee. OCS argued that complying with the notice order would violate federal privacy laws, but the court modified its order to address these concerns.The Supreme Court of Alaska reviewed the case and affirmed the Superior Court’s conclusions. The Supreme Court held that the due process claim and the court’s notice order were not preempted by federal law. The court determined that foster children have a property interest in knowing about their Social Security benefits and the ability to nominate a private payee. The court found that OCS’s systematic practice of using benefits to reimburse itself without notice created a high risk of depriving children of their rights.The Supreme Court also held that the equal protection claim was preempted because it would conflict with federal regulations governing the use of Social Security benefits. The court concluded that OCS’s practice of using benefits for foster care costs was permissible under federal law. Finally, the court rejected the proposed remedies of disgorgement and creating a trust, as they would constitute impermissible attachments on federal benefits and were preempted by federal law. View "State of Alaska, Department of Health and Social Services v. Z. C." on Justia Law

Several unemployed workers in Alabama applied for unemployment benefits and claimed that the Alabama Department of Labor unlawfully delayed processing their claims. They sued the Alabama Secretary of Labor in state court under 42 U.S.C. §1983, arguing that the delays violated their due process and federal statutory rights. They sought a court order to expedite the processing of their claims. The Secretary moved to dismiss the complaint, arguing that the claimants had not satisfied the administrative-exhaustion requirement under Alabama law. The state trial court granted the motion and dismissed the complaint.The claimants appealed to the Alabama Supreme Court, which affirmed the dismissal on the grounds of failure to exhaust administrative remedies. The court concluded that §1983 did not preempt the state's administrative-exhaustion requirement, effectively preventing the claimants from suing to expedite the administrative process until they had completed it.The Supreme Court of the United States reviewed the case and held that state courts may not deny §1983 claims on failure-to-exhaust grounds when the application of a state exhaustion requirement effectively immunizes state officials from such claims. The Court reasoned that Alabama's exhaustion requirement, as applied, prevented claimants from challenging delays in the administrative process, thus immunizing state officials from §1983 suits. The Court reversed the Alabama Supreme Court's decision and remanded the case for further proceedings consistent with its opinion. View "Williams v. Reed" on Justia Law

Louisiana Fair Housing Action Center (LaFHAC) sued Azalea Garden Properties, LLC (Azalea Garden), alleging that Azalea Garden discriminated on the basis of race and disability at its apartment complex in Jefferson, Louisiana, in violation of the Fair Housing Act (FHA). The district court dismissed LaFHAC’s disability claim but allowed its disparate impact race claim to proceed, subject to one caveat: The district court certified a permissive interlocutory appeal on the issue of whether the “predictably will cause” standard for FHA disparate-impact claims remains viable after Inclusive Communities Project Inc. v. Lincoln Property Co., 920 F.3d 890 (5th Cir. 2019).   The Fifth Circuit remanded the case with instructions to dismiss LaFHAC’s claims without prejudice. The court held that the district court lacked jurisdiction over this case. Along the same lines, the court wrote that it cannot consider the district court’s certified question. The court explained that LaFHAC has plausibly alleged a diversion of resources, as it shifted efforts away from planned projects like its annual conference toward counteracting Azalea Garden’s alleged discrimination. But “an organization does not automatically suffer a cognizable injury in fact by diverting resources in response to a defendant’s conduct.” The court wrote that LaFHAC failed to plead an injury because it failed to allege how its diversion of resources impaired its ability to achieve its mission. Thus, the court held that because LaFHAC has not alleged a cognizable injury, it lacks standing to bring the claims it alleges in this action. View "LA Fair Housing Action v. Azalea Garden" on Justia Law

The Supreme Court dismissed this direct appeal brought by the Iowa Department of Human Services (HDS) from a district court ruling requiring Iowa's Medicaid program to pay for sex reassignment surgery for two transgender adults and affirmed the denial of fees on cross-appeal, holding that the appeal was moot.Petitioners, adult transgender Iowans who were denied preauthorization for sex reassignment surgeries through the Medicaid program, appealed their managed care organization's denial of coverage to DHS. DHS affirmed the denials. The district court reversed, concluding that Iowa Code 216.7(3), an amendment to the Iowa Civil Rights Act (ICRA) violated the guarantee of equal protection under the Iowa Constitution. DHS appealed, but, thereafter, agreed to pay for Petitioners' surgeries. The Supreme Court dismissed the direct appeal as moot and affirmed the district court's order denying any fee award, holding that the court erred in denying Petitioners' request for attorney fees. View "Vasquez v. Iowa Dep't of Human Services" on Justia Law

In 1993, Kastman was charged with misdemeanor offenses based on acts of public indecency involving children and disorderly conduct. The state’s attorney initiated a civil commitment proceeding against Kastman under the Sexually Dangerous Persons Act (725 ILCS 205/0.01). Evidence indicated that Kastman suffered from pedophilia, antisocial personality disorder, exhibitionism, and alcohol dependency. Kastman was found to be a sexually dangerous person, and the circuit court granted the petition. In 2016, Kastman was granted conditional release from institutional care.In 2020, he sought financial assistance. Kastman asserted that he was unemployed, disabled, and could not afford his $300 monthly treatment costs and the $1800 monthly rent for housing that complied with the Sex Offender Registration Act. The circuit court of Lake County ordered the Department of Corrections to pay a portion of Kastman’s monthly expenses. The appellate court and Illinois Supreme Court affirmed. The statutes indicate that a sex offender’s ability to pay is a relevant consideration in deciding who should bear the expense of treatment costs; without a clear statutory directive, the legislature is not presumed to have intended that only financially stable individuals are eligible for conditional release. Financial instability and the need for supervision to protect the public are not the same things. View "People v. Kastman" on Justia Law

The Ninth Circuit reversed in part and vacated in part the district court’s grant of Defendants’ motion to dismiss, and remanded for further proceedings, in an action in which federally-qualified health centers operating in Arizona and their membership organization alleged that the Arizona Health Care Cost Containment System, which administers Arizona’s Medicaid program, and its director violated 42 U.S.C. Section 1396a(bb) and binding Ninth Circuit precedent by failing or refusing to reimburse Plaintiffs for the services of dentists, podiatrists, optometrists, and chiropractors.   First, the panel held that the court’s precedent in California Ass’n of Rural Health Clinics v. Douglas (“Douglas”), 738 F.3d 1007 (9th Cir. 2013), established that FQHC services are a mandatory benefit under Section 1396d(a)(2)(C) for which Plaintiffs have a right to reimbursement under Section 1396a(bb) that is enforceable under 42 U.S.C. Section 1983. The panel rejected Defendants’ interpretation of Section 1396d(a)(2)(C)’s phrase “which are otherwise included in the plan” as applying to both the phrases “FQHC services” and “other ambulatory services offered by a [FQHC.]” The panel, therefore, rejected Defendants’ assertion that Section 1396d(a)(2)(C) only required states to cover FQHC services that are included in the state Medicaid plan.   The panel recognized that Douglas held that the mandatory benefit of “FQHC services” under § 1396d(a)(2)(C) includes “services furnished by . . . dentists, podiatrists, optometrists, and chiropractors” as well as doctors of medicine and osteopathy. The panel held that Arizona’s categorical exclusion of adult chiropractic services violated the unambiguous text of the Medicaid Act as interpreted in Douglas. View "AACHC V. AHCCCS" on Justia Law