Justia Public Benefits Opinion Summaries

Plaintiffs brought this action for damages under 42 U.S.C. 1983 on behalf of their minor daughter, who allegedly was deprived of her constitutional rights when she was expelled from public school and refused alternative education benefits during the 2005-2006 academic school year by defendants. The district court granted summary judgment in favor of defendants dismissing all of plaintiffs' claims. The court affirmed the district court's summary judgment in principal part, but reversed summary judgment with respect to plaintiffs' claims that their daughter was deprived of her constitutional right to procedural due process when defendants denied her right under state law to continued public educational benefits through an alternative education program without some kind of notice and some kind of hearing. Accordingly, the court remanded the case to the district court for further proceedings.

Plaintiff, a minor with dyslexia, by and through her mother and Guardian Ad Litem, appealed from the district court's order affirming the Administrative Hearing Officer's conclusion that the Hawaii Department of Education (DOE) properly found plaintiff ineligible for services under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court held that the DOE procedurally violated the IDEA by applying regulations that required exclusive reliance on the "severe discrepancy model" at plaintiff's final eligibility meeting. This violation deprived plaintiff of a significant educational opportunity because it resulted in an erroneous eligibility determination. Accordingly, the court reversed the district court's order affirming the Hearing Officer's decision and remanded for further proceedings.

Appellee applied for supplemental security income under Title XVI of the Social Security Act, 42 U.S.C. 1382. The Commissioner of the Social Security Administration subsequently appealed the district court's decision, arguing that the ALJ permissibly discounted appellee's testimony and that the district court substituted its own judgment for that of the ALJ in concluding otherwise. In the alternative, the Commissioner asserted that even if the ALJ erred, the district court should have remanded for additional proceedings and erred in directing the entry of an award of benefits. The court held that valid reasons supported the ALJ's adverse credibility determination and that substantial evidence in the record supported the ALJ's determination that appellee could perform sedentary work as long as he had the option of alternating between sitting and standing. Therefore, the court reversed the district court's decision and remanded for the district court to affirm the decision of the Commissioner.

Plaintiff, an unincorporated association made up of homeless and formerly homeless people that advocated for their rights, sued defendants, alleging that defendants had conspired to establish the Conrad Center on Oliver Hill Way, a site removed from Richmond's downtown community, for the purpose of reducing the presence of the homeless population in the downtown area by providing services for them in a remote location. Plaintiff claimed that the relocation of homeless services to the Conrad Center violated 42 U.S.C. 1983 and 1985(3); the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq.; the Equal Protection Clause of the Fourteenth Amendment; and the Fair Housing Act (FHA), 42 U.S.C. 3601 et seq. The court held that plaintiff did not state a valid section 1985(3) conspiracy claim; plaintiff's 1983 and equal protection claims were barred by the applicable statute of limitations; plaintiff's FHA claims were barred by the two-year statue of limitations and, more fundamentally, they failed to state a claim upon which relief could be granted; and plaintiff's ADA retaliation claim was properly dismissed. Accordingly, the court affirmed the judgment of the district court.

Plaintiffs, a class of economically vulnerable Arizonians who receive public health care benefits through the state's Medicaid agency, sued the U.S. Secretary of Health and Human Services (Secretary) and the Director of Arizona's medicaid agency (director)(collectively, defendants), alleging that the heightened mandatory co-payments violated Medicaid Act, 42 U.S.C. 1396a, cost sharing restrictions, that the waiver exceeded the Secretary's authority, and that the notices they received about the change in their health coverage was statutorily and constitutionally inadequate. The court affirmed the district court's conclusion that Medicaid cost sharing restrictions did not apply to plaintiffs and that Arizona's cost sharing did not violate the human participants statute. The court reversed the district court insofar as it determined that the Secretary's approval of Arizona's cost sharing satisfied the requirements of 42 U.S.C. 1315. The court remanded this claim with directions to vacate the Secretary's decision and remanded to the Secretary for further consideration. Finally, the court remanded plaintiffs' notice claims for further consideration in light of intervening events.

Defendant Daniel Cadle appealed a district court order that confirmed an arbitration award against him on Plaintiff Kerry Hicks’s claims of defamation and intentional infliction of emotional distress. Defendant’s objections concerned whether the dispute was properly referred to arbitration. The district court rejected Defendant’s objections for various reasons, holding that he was judicially estopped from challenging the arbitrator’s authority and that the dispute was properly referred to arbitration. Upon review of the lower court record, the Tenth Circuit affirmed the district court’s decision, holding judicial estoppel prevented Defendant from raising the arbitration issue on appeal. The Court declined to address issues unrelated to that rationale and dismissed Defendant’s case.

Plaintiff-Appellant Debra Kruse appealed the Commissioner of Social Security’s denial of benefits, claiming that an Administrative Law Judge (ALJ) erred in considering her medical source evidence and her credibility. Plaintiff claimed she was disabled by panic disorder, depression, joint disease and foot edema. She applied for Supplemental Security Income, but the ALJ concluded she was not disabled. Upon review of the ALJ’s decision and the applicable legal authority, the Tenth Circuit affirmed the Commission’s determination, finding substantial evidence and analysis to support the ALJ’s decision.

Plaintiff-Appellant Jeffrey McFerran appealed a district court judgment that affirmed the Commissioner of Social Security’s denial of his application for disability benefits. Plaintiff sought benefits based on degenerative disc disease of the lumbar and cervical spine and associated pain; coronary artery disease; hypertension; obesity; post surgery hernia; knee and shoulder limitations; depression; and anxiety. He had worked for the postal service following 40 years with the Air Force. The Veterans Administration determined Plaintiff was "entitled to receive service connected compensation at the 100 percent rate." An administrative law judge (ALJ) denied benefits at the last step of the five-step sequential process for determining disability. Finding that the Commissioner failed to follow the correct legal standards in denying benefits, the Tenth Circuit reversed Plaintiff’s case and remanded it for further proceedings.

Plaintiff-Appellant Patrick Dorman appealed a district court's denial of his request for an Equal Access to Justice (EAJA) fee. Plaintiff filed his application for social security disability benefits in 2004 alleging that he became disabled on December 30, 2003, due to breathing problems and depression. The agency denied his applications initially and on reconsideration. Plaintiff obtained a hearing before an administrative law judge (ALJ) who determined that he could return to his past relevant work and, therefore, upheld the denial of his application. Plaintiff then appealed administratively to the Appeals Council, which denied review of the ALJ’s decision. Plaintiff thereafter unsuccessfully appealed the Council's decision to the district court. Plaintiff then appealed to the Tenth Circuit court, raising essentially the same issues he had presented in the district court but this time focusing his argument on the ALJ’s failure to properly evaluate his mental impairments. The Tenth Circuit found merit to Plaintiff's argument and overturned the lower courts' decisions. Plaintiff's counsel thereafter petitioned the district court for an award of EAJA fees. Upon review, the Tenth Circuit concluded the district court abused its discretion in denying Plaintiff's EAJA fee motion. Consequently, the Court reversed the district court’s denial of his EAJA motion for fees and costs, and remanded the case with instructions to grant the motion and to award a reasonable fee and appropriate costs to Plaintiff.

Petitioner Patricia Kalar petitioned the Supreme Court to challenge the reduction of her benefits by Respondent New Hampshire Department of Health and Human Services. The Department conducted an inquiry into Petitioner's income and expenses as part of a mandatory, periodic "recertification" process for determining Petitioner's food stamp benefits. At the last inquiry, the Department determined that Petitioner's food stamp benefit should be reduced. Petitioner argued on appeal that the Department erred in its calculation that served as the basis of its reduction determination. Upon review, the Supreme Court could not conclude that the reduction in Petitioner's benefits was due to miscalculations by the Department. The Court affirmed the Department's decision.