Justia Public Benefits Opinion Summaries

Plaintiff, proceeding pro se, filed suit against multiple private entities and government officials, including, as relevant to the instant appeal, the Social Security Commissioner, a Social Security claims representative, the Secretary of the Treasury, and the Secretary of Education (the “Federal Defendants”), asserting a number of claims relating to the Social Security Administration’s (SSA) allegedly improper withholding of his disability benefits.   The Fifth Circuit affirmed. The court concluded that it did not have subject matter jurisdiction over Mr. Chambers’ claims against the Social Security Administration representatives concerning his Social Security benefits and that Plaintiff has failed to state a claim as to its remaining claims against the Federal Defendants. The court explained that while the lack of jurisdiction is a sufficient basis on which to affirm the district court, Plaintiff’s broad challenges to “any of [the court’s] holdings dismissing the federal government defendants” warrant but a brief note. The court found no error in the district court’s dismissal of the Treasury Secretary, given its purely ministerial role in administering the offset for Plaintiff’s outstanding loan, or its dismissal of the Secretary of Education, given Plaintiff’s similar failure to exhaust administrative remedies with that department and failure to advance a colorable constitutional violation. View "Chambers v. Kijakazi" 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

Appellants challenged the appointment of Social Security Administration Acting Commissioner Nancy Berryhill under the Federal Vacancies Reform Act (FVRA). They argue that no one may serve as an acting officer under 5 U.S.C. Section 3346(a)(2), which allows acting service while a nomination is pending in the Senate unless that nomination occurred during the initial 210-day period of acting service allowed by 5 U.S.C. Section 3346(a)(1). Appellants assert that Section 3346(a)(2) serves only to toll Section 3346(a)(1)’s time limit and does not authorize an independent period of acting service.   The Fourth Circuit affirmed. The court rejected Appellants’ argument because Section 3346(a)(1) and Section 3346(a)(2) are, by their plain text, disjunctive and independent. Because Berryhill was legally serving as Acting Commissioner, her appointments of the ALJs who decided Appellants’ cases were valid. The court explained that Appellants’ reading of the statute would shift the balance against the President. It would prevent him from designating anyone to serve as an acting officer if he submits a nomination after the 210-day period has elapsed, thus leaving the office vacant for as long as the Senate takes to consider it. View "Barbara Rush v. Kilolo Kijakazi" on Justia Law

More than a decade ago, Medicaid recipients filed this suit alleging that in violation of the Due Process Clause, the District of Columbia is failing to provide them notice and an opportunity to be heard when denying them prescription coverage. The case is now before the DC Circuit for the third time. In the first two appeals, the DC Circuit reversed the district court’s dismissals for lack of standing and for failure to state a claim, respectively. On remand, the district court once more dismissed the case, this time for mootness.   The DC Circuit again reversed and remanded with instructions to proceed expeditiously with discovery and allow Plaintiffs to make their case. The court explained that Plaintiffs challenged the District’s failure to give Medicaid recipients reasons for denying their prescriptions and an explanation of how to appeal, and uncontested evidence demonstrates that, notwithstanding the transmittal memorandum, some number of Plaintiffs are still not receiving the information they claim they are entitled to under the Due Process Clause. Because it is not “impossible for [the district] court to grant any effectual relief,” the case is not moot. View "Elsa Maldonado v. DC" on Justia Law

Plaintiff applied for and was denied disability benefits from the Social Security Administration (“SSA”). Plaintiff appealed the decision to the District of Minnesota, arguing in part that the Administrative Law Judge (“ALJ”) who oversaw the case lacked authority because SSA Acting Commissioner Nancy Berryhill was not properly serving as Acting Commissioner when she ratified the ALJ’s appointment. The district court agreed.   The Eighth Circuit reversed. The court found that Berryhill was properly serving as Acting Commissioner when she ratified the appointment. Plaintiff argued the district court’s decision can be affirmed because Berryhill was never directed to serve by the president. In essence, he argued the 2016 succession memo became null and void when administrations changed in 2017. The court concluded that this argument fails. The general rule is that presidential orders without specific time limitations carry over from administration to administration. Plaintiff provides no authority indicating succession orders are any different from other presidential orders. The text of the FVRA likewise does not change the default position that presidential orders, including succession memos under the FVRA, carry over from one administration to the next. View "Brian Dahle v. Kilolo Kijakazi" on Justia Law

Securus Technologies, LLC (Securus), is one of six telecommunications companies providing incarcerated persons calling services (IPCS) in California. In this original proceeding, Securus challenges the decision of the California Public Utilities Commission (PUC) adopting interim rate relief for IPCS in the first phase of a two-phase rulemaking proceeding. Among other things, the PUC’s decision: (1) found IPCS providers operate as locational monopolies within the incarceration facilities they serve and exercise market power; (2) adopted an interim cap on intrastate IPCS rates of $0.07 per minute for all debit, prepaid, and collect calls; and (3) prohibited providers from charging various ancillary fees associated with intrastate and jurisdictionally mixed IPCS.   The Second Appellate District affirmed the PUC’s decision. The court concluded Securus has not shown the PUC erred by finding providers operate locational monopolies and exercise market power. The court held that facts do not—as Securus contends—demonstrate Securus “cannot recover its costs (including a reasonable rate of return)” under the interim rate cap and do not amount to a “clear showing” that a rate of $0.07 per minute “is so unreasonably low” that “it will threaten Securus’s financial integrity.” Thus, Securus has failed to satisfy its “burden of proving . . . prejudicial error” on constitutional grounds. View "Securus Technologies v. Public Utilities Com." on Justia Law

Plaintiff appealed the district court’s order affirming the Social Security Administration’s (“SSA”) denial of her application for Social Security Disability Insurance (“SSDI”). In her application, she alleged major depressive disorder (“MDD”), anxiety disorder, and attention deficit disorder (“ADHD”). Following a formal hearing, the Administrative Law Judge (“ALJ”) determined that Plaintiff suffered from severe depression with suicidal ideations, anxiety features and ADHD, but he nonetheless denied her claim based on his finding that she could perform other simple, routine jobs and was, therefore, not disabled. Plaintiff contends that the ALJ erred by (1) according to only little weight to the opinion of her long-time treating psychiatrist (“Dr. B”) and (2) disregarding her subjective complaints based on their alleged inconsistency with the objective medical evidence in the record.   The Fourth Circuit reversed and remanded with instructions to grant disability benefits. The court agreed with Plaintiff that the ALJ failed to sufficiently consider the requisite factors and record evidence by extending little weight to Dr. B’s opinion. The ALJ also erred by improperly disregarding Plaintiff’s subjective statements. Finally, the court found that the ALJ’s analysis did not account for the unique nature of the relevant mental health impairments, specifically chronic depression. The court explained that because substantial evidence in the record clearly establishes Plaintiff’s disability, remanding for a rehearing would only “delay justice.” View "Shelley C. v. Commissioner of Social Security Administration" on Justia Law

Plaintiff appealed from the 2021 opinion of the district court affirming the final decision of Defendant Kijakazi, as the Acting Commissioner of Social Security, which denied Plaintiff’s claim for disability benefits.   The Fourth Circuit, without resolving the merits, vacated the judgment of the district court and directed a remand to the Commissioner for a new and plenary hearing on Plaintiff’s disability benefits claim, to be conducted before a different and properly appointed administrative law judge (ALJ). The court agreed with Plaintiff’s appellate contention that, pursuant to the Supreme Court’s 2018 decision in Lucia v. SEC, 138 S. Ct. 2044 (2018), the (“ALJ Bright”) who rendered the Commissioner’s final decision did so in contravention of the Constitution’s Appointments Clause.   The court explained that the Supreme Court made clear that if an ALJ makes a ruling absent a proper constitutional appointment, and if the claimant interposes a timely Appointments Clause challenge, the appropriate remedy is for the claim to be reheard before a new decisionmaker. Plaintiff did not receive that remedy. The Appointments Clause violation as to Plaintiff was thus not cured, and the 2019 ALJ Decision was likewise rendered in contravention of that Clause. View "Camille Brooks v. Kilolo Kijakazi" on Justia Law

The First Circuit affirmed the judgment of the district court determining that Act 90, passed by the Legislative Assembly of Puerto Rico in 2019, was preempted by federal law, holding that the district court did not err.Act 90 requires that Medicare Advantage plans compensate Puerto Rico healthcare providers in Puerto Rico at the same rate as providers are compensated under traditional Medicare. Plaintiffs, several entities that managed Medicare Advantage plans, filed suit seeking a declaratory judgment and an injunction barring the "mandated price provision," arguing that the Medicare Advantage Act preempted the challenged provision and that provision was unconstitutional. The district court ruled in favor of Plaintiffs. The First Circuit affirmed, holding that Act 90's mandated price provision was preempted by federal law. View "Medicaid & Medicare Advantage Products Ass'n of Puerto Rico, Inc. v. Emanuelli-Hernandez" on Justia Law