Justia Public Benefits Opinion Summaries

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.

Plaintiff, an eleven-year-old special education student, lived in the Minnesota Independent School District No. 15 (district). An ALJ for the Minnesota Department of Education determined that the district had denied plaintiff a free appropriate public education (FAPE) within the meaning of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1482. After plaintiff filed an action in federal court seeking attorney fees and costs, both parties filed cross-motions for judgment on the administrative record. The district court reversed the ALJ's decision and denied plaintiff's motion for fees and costs and plaintiff appealed. The court affirmed the district court's judgment and held that plaintiff was not denied a FAPE where the district court did not fail to give "due weight" to the results of the administrative hearing; where the district court did not commit procedural violations of the IDEA; and where the district court did not violate the IDEA's substantive requirements.

The court agreed to rehear this case en banc to clarify under what circumstances the exhaustion requirement of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1415(l), barred non-IDEA federal or state law claims. Plaintiff, on behalf of herself and her son, appealed the district court's grant of summary judgment to defendants where the district court dismissed her claims for lack of subject matter jurisdiction because plaintiff did not initially seek relief in a due process hearing and therefore, failed to comply with one of the exhaustion-of-remedies requirement of the IDEA. The court held that the IDEA's exhaustion requirement was not jurisdictional and that plaintiff's non-IDEA federal and state-law claims were not subject to the IDEA's exhaustion requirement. Therefore, the court reversed the judgment.

Plaintiffs, visually or manually impaired Florida citizens who were registered to vote in Duval County, Florida and were represented by the American Association of People with Disabilities, filed a putative class action against defendants, alleging that defendants violated federal statutory and state constitutional provisions by failing to provide handicapped-accessible voting machines to visually or manually impaired Florida voters after the 2000 general election. The court vacated its prior opinion and in its revised opinion, held that the district court erroneously granted plaintiffs' requested declaratory judgment and injunction against purported violations of the American with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101-12213, and the regulations promulgated thereunder. The opinion, however, based that outcome exclusively on the ground that voting machines were not "facilities" under 28 C.F.R. 35.151(b).

Plaintiffs, visually or manually impaired Florida citizens who were registered to vote in Duval County, Florida and were represented by the American Association of People with Disabilities, filed a putative class action against defendants, alleging that defendants violated federal statutory and state constitutional provisions by failing to provide handicapped-accessible voting machines to visually or manually impaired Florida voters after the 2000 general election. The court vacated its prior opinion and in its revised opinion, held that the district court erroneously granted plaintiffs' requested declaratory judgment and injunction against purported violations of the American with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101-12213, and the regulations promulgated thereunder. The opinion, however, based that outcome exclusively on the ground that voting machines were not "facilities" under 28 C.F.R. 35.151(b).

Appellant appealed the district court's judgment upholding the Commissioner of Social Security's denial of his application for disability insurance and supplemental security income (SSI) benefits, under Title II and XVI of the Social Security Act (SSA), 42 U.S.C. 301 et seq. The court held that substantial evidence on the record supported the ALJ's finding that appellant's depression and anxiety were not severe; that the ALJ did not err in evaluating appellant's credibility; that, while the ALJ did not explicitly address the claims of appellant's girlfriend, the ALJ's error had no bearing on the outcome of appellant's case and did not require remand; and that the vocational expert's answer to a hypothetical question was not improper and constituted substantial evidence supporting the ALJ's determination. Accordingly, the court affirmed the judgment.