Justia Public Benefits Opinion Summaries

Planned Parenthood and others filed suit challenging Ariz. Rev. Stat. 35-196.05(B) as a violation of the federal Medicaid Act, 42 U.S.C. 1396a. Ariz. Rev. Stat. 35-196.05(B) barred patients eligible for the state's Medicaid program from obtaining covered family planning services through health care providers who performed abortions in cases other than medical necessity, rape, or incest. The court concluded that the district court's entry of final judgment and a permanent injunction mooted Arizona's appeal of the district court's preliminary injunction. Therefore, the court dismissed that appeal (Case No. 12-17558), and considered only Arizona's appeal of the summary judgment order and permanent injunction (Case No. 13-15506). The court held that the Medicaid Act's free-choice-of-provider requirement conferred a private right of action under 42 U.S.C. 1983. The court also held that the Arizona statute contravenes the Medicaid Act's requirement that states give Medicaid recipients a free choice of qualified provider. Accordingly, the court affirmed the district court's summary judgment and permanent injunction. View "Planned Parenthood v. Betlach" on Justia Law

Plaintiff filed suit against the district alleging claims for disability discrimination and failure to accommodate under the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101-12213. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of the district. The court concluded that the district court did not abuse its discretion by reconsidering its prior order denying summary judgment where the district court found that it had committed clear error by not considering whether plaintiff gave a sufficient explanation for the conflict between her ADA claim and her Nevada Public Employees' Retirement Systems (PERS) application under the Supreme Court's decision in Cleveland v. Policy Mgmt. Sys. Corp. Under the standard set forth in Cleveland, the court concluded that plaintiff gave sufficient explanations for the inconsistencies between her ADA claim and her PERS and Family Medical Leave Act (FMLA), 29 U.S.C. 2601, applications to survive summary judgment. Accordingly, the court affirmed in part and reversed in part, remanding for further proceedings. View "Smith v. Clark County School District" on Justia Law

Plaintiff, a severely disabled student, filed suit arguing that he was entitled to remain at a private school he had been attending since the age of seven. The Department issued a formal notice that plaintiff's special education placement at the school would end when he turned 20 years old. Plaintiff argued that he was entitled to remain at the school until he was 22 years old. At issue on appeal was whether the "stay put" provision in the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1415j, applied to a student who has exceeded a state-imposed age limit on eligibility for public education. The court affirmed the judgment of the district court, concluding that the district court correctly granted plaintiff's motion for stay put. Plaintiff was entitled to remain at the school as his stay-put placement from the date he filed his administrative complaint and he was entitled to remain there until his case was finally resolved. View "A.D. v. State of Hawaii Dep't of Educ." on Justia Law

Plaintiffs filed a due-process complaint against the DOE seeking tuition reimbursement after plaintiffs enrolled their autistic child in a private school because the DOE failed to provide the child with a free and appropriate public education under the Individuals with Disabilities Education Improvement Act (IDEA), 20 U.S.C. 1400 et seq. The court affirmed the state review officer's determination that the hearing record did not support the impartial hearing officer's determination that the lack of a functional behavior assessment (FBA) rose to the level of denying the child a free and appropriate public education (FAPE) where the individualized education program (IEP) addressed behavioral needs. Further, the IEP's failure to include parental counseling did not deny the child a FAPE; the SRO did not rely upon impermissible retrospection and the court deferred to her analysis; and the court found plaintiffs' remaining arguments to be without merit. Accordingly, the court affirmed the grant of summary judgment in favor of defendants. View "M.W. v. New York City Dep't of Educ." on Justia Law

Plaintiff, a recipient of Supplemental Security Income (SSI) benefits, appealed from the district court's judgment sua sponte dismissing his amended complaint under 28 U.S.C. 1915(e)(2)(B). Plaintiff sought an Order to Show Cause, a temporary restraining order, and a preliminary injunction enjoining defendants from levying against his SSI benefits to enforce a child support order. At issue was whether 42 U.S.C. 659(a) authorized levy against SSI benefits provided under the Social Security Act, 42 U.S.C. 301 et seq., to satisfy the benefits recipient's child support obligations. The court concluded that SSI benefits were not based upon remuneration for employment within the meaning of section 659(a); section 659(a) did not preclude plaintiff's claims; and the Rooker-Feldman doctrine and the exception to federal jurisdiction for divorce matters did not preclude the district court from exercising jurisdiction over the matter. Accordingly, the court vacated the judgment to the extent the district court dismissed plaintiff's claims against the agency defendants and remanded for further proceedings. However, the court affirmed the portion of the judgment dismissing plaintiff's claims against Bank of America because his complaint had not alleged facts establishing that the bank was a state actor for purposes of 42 U.S.C. 1983. View "Sykes v. Bank of America" on Justia Law

The Clinics filed suit challenging California Welfare and Institutions Code 14131.10, which eliminated certain Medi-Cal benefits that the state deemed optional, including adult dental, podiatry, optometry, and chiropractic services. The court reversed the district court's holding that the Clinics have a private right of action to challenge the Department's implementation of the state plan amendments (SPA) prior to obtaining approval; affirmed that the Clinics have a private right of action to bring a claim pursuant to 42 U.S.C. 1983 challenging the validity of section 14131.10; and reversed the district court's interpretation of the Medicaid Act, 42 U.S.C. 1396 et seq., holding that section 14131.10 impermissibly eliminated mandatory services from coverage. View "California Ass'n of Rural Health Clinics v. Douglas" on Justia Law

Plaintiff, by and through her adoptive parents, brought this action challenging South Carolina's reduction of monthly adoption assistance benefits, claiming that the reduction violated the Adoption Assistance and Child Welfare Act, 42 U.S.C. 670 et seq. The court held in this case that section 673(a)(3) did set forth a privately enforceable right under 42 U.S.C. 1983, but that the parents have failed to plead any violation of that right by defendants. Accordingly, the court reversed and remanded. View "Hensley v. Koller" on Justia Law

Plaintiff appealed the termination of her Medicaid benefits. At issue was the enforceability of a provision of the Medicaid Act, 42 U.S.C. 1396a(a)(8), under 42 U.S.C. 1983. The court concluded that section 1396a(a)(8) created a right enforceable under section 1983, and that exhaustion of Louisiana's procedure for judicial review was not required before a Medicaid claimant filed suit in federal court. Accordingly, the court affirmed the judgment of the district court denying DHH's motion to dismiss because plaintiff's claims were properly before the district court. View "Romano v. Greenstein" on Justia Law

Plaintiff-Appellant Tyla Newbold appealed a magistrate judge's order that granted her Social Security benefits from October 2006 to November 2007, but denied them thereafter. The Commissioner of the Social Security Administration determined Plaintiff had been disabled during that period due to physical and mental impairments, but that she recovered and the disability ceased. The issue on appeal to the Tenth Circuit was whether the administrative law judge (ALJ) used the proper medical-improvement standard in deciding Plaintiff ceased being disabled. Finding that the ALJ used the proper standard, the Tenth Circuit affirmed. View "Newbold v. Astrue" on Justia Law

Plaintiffs appealed the Secretary's denial of their claims for Medicare coverage for dental services. Plaintiffs contended that this denial was premised on the Secretary's unreasonable interpretation of the Medicare Act, Pub. L. No. 89-97, 79 Stat. 286, which contravened the intent of Congress and violated plaintiffs' right to equal protection under the Fifth Amendment. The court concluded that, although the statutory provision for exclusion of dental services was ambiguous in the sense that plausible divergent constructions could be urged, the Secretary's interpretation of the statute was reasonable. The court also concluded that the Secretary's statutory interpretation warranted Chevron deference and the Secretary's statutory interpretation was reasonable. Accordingly, the court affirmed the judgment. View "Fournier v. Sebelius" on Justia Law