Justia Public Benefits Opinion Summaries

This case began as a dispute over the results of CM's special education evaluation under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. At issue on appeal was: (1) the ALJ's dismissal of several of CM's claims against Lafayette prior to holding a due process hearing; and (2) the district court's dismissal of MM's, CM's parents, separate claims against the California Department of Education (CDE). The court held that the district court correctly dismissed MM's claims against Lafayette challenging the ALJ's statute of limitations ruling as being premature. The district court did not abuse its discretion in dismissing the fourth claim as duplicative and correctly held that the CDE had no authority to oversee the individual decisions of OAH's hearing officers. Accordingly, the court affirmed the judgment of the district court. View "M. M., et al. v. Lafayette Sch. Dist., et al." on Justia Law

T.B.'s parents, on behalf of their autistic child, appealed the district court's finding that the school district did not violate the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., by failing to provide a free appropriate public education (FAPE) to T.B., making the parents ineligible for reimbursement for the costs of T.B.'s home-based program. Given the parents' decision to ultimately settle the issue of the adequacy of the proposed individualized education program (IEP), the court questioned whether they could claim, much less successfully show, that the school district failed to provide a FAPE to T.B. Nonetheless, based on the record, the court could not say that T.B.'s home-based program was "reasonably calculated to enable [him] to receive educational benefits." The program was therefore not "proper" within the meaning of the IDEA and the parents were not entitled to reimbursement for the costs associated with it. Accordingly, the court affirmed the judgment. View "T.B., et al. v. St. Joseph School District" on Justia Law

Plaintiffs, parents of children who were eligible to receive a free and appropriate public education, filed suit to challenge the exclusion of mapping of cochlear implants from the regulatory definition of "related services" under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1401(26)(B). The court concluded that the phrase "audiology services" as used in the IDEA's "related services" definition did not unambiguously encompass mapping of cochlear implants. The court also found that the Mapping Regulations embodied a permissible construction of the IDEA because they were rationally related to the underlying objectives of the IDEA. The court further found that the Mapping Regulations did not substantially lessen the protections afforded by the 1983 regulations. Because the Department's construction of its own regulation was neither plainly erroneous nor inconsistent with the regulation, the court owed it deference. Accordingly, the court affirmed the district court's grant of summary judgment to the Department. View "Petit, et al. v. US Dept. of Education, et al." on Justia Law

This case arose when plaintiffs filed a class action complaint under 42 U.S.C. 1983, alleging that the District was violating the Medicaid Act, 42 U.S.C. 1396 et seq. Since 1993, a consent decree has governed how the District provides "early and periodic screening, diagnostic, and treatment services" under the Act. The District has now asked the district court to vacate that decree on two grounds: that an intervening Supreme Court decision has made clear that plaintiffs lack a private right of action to enforce the Medicaid Act, and that in any event, the District has come into compliance with the requirements of the Act. Because the court concluded that the district court's rejection of one of the District's two arguments did not constitute an order "refusing to dissolve [an] injunction[]" within the meaning 28 U.S.C. 1292(a)(1), the court dismissed the appeal for lack of jurisdiction. View "Salazar, et al. v. DC, et al." on Justia Law

Appellants are the parents of G.J., a child with autism and brain injuries. At issue was whether the ALJ and the district court properly evaluated appellants' claims that the MCSD did not comply with certain provisions of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., with respect to services it was to provide to G.J. The court held that the district court did not err in setting forth reasonable conditions for G.J.'s reevaluation and in determining that appellants were not entitled to either a private or publicly funded independent educational evaluation. The court also held that there was no basis for making a determination that any procedural failures with regard to the August 2008 and 2009 IEP meetings impacted the education received by G.J. to any substantive degree. Accordingly, the judgment was affirmed. View "G. J., et al. v. Muscogee Co. Sch. Dist." on Justia Law

Defendant filed a due process hearing complaint with California's Office of Administrative Hearings (OAH), alleging that he was being denied the free appropriate public education (FAPE) that he was entitled to under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court certified the following question to the California Supreme Court: Does California Education Code 56041 - which provided generally that for qualifying children ages eighteen to twenty-two, the school district where the child's parent resides is responsible for providing special education services - apply to children who are incarcerated in county jails? The case was withdrawn from submission and further proceedings were stayed pending final action by the Supreme Court of California. View "Los Angeles Unified Sch. Dist. v. Garcia" on Justia Law

In 2003, the New Hampshire Department of Health and Human Services and a certified class of Medicaid-eligible children reached a settlement agreement and proposed a consent decree that outlined the Department's obligations to provide dental services to Medicaid-enrolled children in accordance with federal law. The district court approved the Decree in 2004. Between 2007 and 2010, the district court denied four motions alleging that the Department was not in compliance. The First Circuit affirmed, upholding the district court's requirement that the Class to file a motion for contempt to enforce the Decree; denial of a 2010 motion for contempt; denial of a request for an evidentiary hearing in 2010; and holding the Class to a clear and convincing burden of proof on its 2010 motion to modify or extend the Decree. View "Hawkins v. Dep't of Health & Human Servs. for the State of NH" on Justia Law

This case involved Commonwealth Care, a state-initiated program that provided structured premium assistance for low-income Massachusetts residents. In 2009, the Legislature made certain changes to the eligibility requirements of Commonwealth Care, enacted in a two-part supplemental appropriation for fiscal year 2010. Section 31(a) of the appropriation excluded all aliens who were federally ineligible under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), 8 U.S.C. 1601-1646, from participation in Commonwealth Care. Plaintiffs were individuals who either have been terminated from Commonwealth Care or have been denied eligibility solely as a result of their alienage. The court held that section 31(a) could not pass strict scrutiny and that the discrimination against legal immigrants that its limiting language embodied violated their rights to equal protection under the Massachusetts Constitution. View "Finch & others v. Commonwealth Health Ins. Connector Auth. & others" on Justia Law

Plaintiff appealed the district court's order affirming the Commissioner's denial of her application for supplemental security income (SSI). The court found that substantial evidence supported the ALJ's conclusion that plaintiff was not disabled within the meaning of the Social Security Act, 42 U.S.C. 301 et seq. Accordingly, the court affirmed the district court's grant of judgment on the pleadings in favor of the Commissioner. View "Hancock v. Astrue" on Justia Law

This case involved A.S., a California minor, who was eligible for special education services under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. At issue was which California agency was responsible for funding A.S.'s educational placement in an out-of-state residential treatment facility. The court held as a matter of California law that the California agency responsible for funding A.S.'s education at an out-of-state residential treatment facility was the school district in which the student's parent, as defined by California Education Code section 56028, resided. The court held that A.S. had no parent under the 2005 version of section 56028 and thus, from July 28, 2006, when A.S. was placed at the out-of-state facility, until October 9, 2007, when an amended version of section 56028 took effect, California law did not designate any educational agency as responsible for A.S.'s education. The California Department of Education (CDE) was therefore responsible by default. The court held that A.S. did have a parent under the 2007 and 2009 versions of section 56028. CDE therefore was not responsible for A.S.'s out-of-state education after October 10, 2007, when the 2007 version of section 56028 took effect. Accordingly, the court affirmed in part and reversed in part the district court's judgment. View "Orange County Dept. of Educ. v. CA Dept. of Educ., et al" on Justia Law