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.

Linda Thompson appealed from a Superior Court judgment reversing the determination of the Unemployment Appeals Board (UIAB) that good cause existed for Thompson's voluntary resignation and granting her unemployment benefits. Thompson contended that good cause existed for voluntarily terminating her employment, that she exhausted her administrative remedies, and that substantial evidence in the record supported the UIAB's decision. The court affirmed the judgment of the Superior Court and held that substantial evidence did not support the UIAB's decision and the UIAB erred as a matter of law by concluding that Thompson was entitled to benefits pursuant to 19 Del. C. 3314(1).

Appellant appealed the district court's order, which affirmed the decision of the Commissioner of the Social Security Administration (Commissioner), denying appellant's application for disability benefits (DIB) under Title II of the Social Security Act, 42 U.S.C. 401 et seq. At issue was whether the ALJ committed legal error by failing to correctly apply the requisite five-step sequential evaluation process. The court held that the ALJ's failure to follow the mandated procedure was more than a mere oversight in opinion writing and that the ALJ was required to follow one of two paths at step five of the sequential process and there was no record indicating that the ALJ followed either path. Accordingly, the court reversed the district court's order affirming the Commissioner's decision and instructed the district court to remand the case to the Commissioner for further proceedings.

Defendant was convicted of one count of making a false statement to obtain Social Security Disability benefits and two counts of knowingly concealing that he earned wages above the income threshold for disability benefits. On appeal, defendant argued that his sentence was unreasonable and filed pro se motions seeking reversal. The court held that the district court considered appropriate factors and provided adequate, internally consistent reasons in imposing a reasonable sentence. The court also held that the pro se motions were better left to a collateral proceeding where the court had an undeveloped record on such claims. Accordingly, the judgment of the district court was affirmed.

Appellant challenged a judgment of the district court affirming the Social Security Administration's (SSA) denial of his application for disability benefits. Appellant contended that the ALJ did not properly apply the "treating physician rule" in evaluating his application and further argued that new evidence had come to light that warranted a remand to the agency. The court held that the ALJ did not, as required by the treating physician rule, explain his reasons for rejecting the opinion of appellant's treating physician. The court also held that a letter from the Board of Medicine validating appellant's complaint, as well as a judicial determination that a physician's report contained a false representation, qualified as new evidence within the meaning of 42. U.S.C. 405(g). Therefore, the court reversed the judgment of the district court and remanded for further proceedings.

Appellant alleged that he was disabled as a result of Post Traumatic Stress Disorder, Parkinson's disease, Attention Deficit Disorder, and peripheral neuropathy and that these mental and physical limitations he had as a result of these conditions, combined with his advanced age and limited job skills, rendered him unable to perform any work available in the national economy. Appellant challenged the district court's affirmance of the Social Security Administration's (SSA) denial of his claim for disability benefits. The court affirmed the judgment and held that the ALJ's findings were supported by substantial evidence.