Justia Public Benefits Opinion Summaries

In 1988, an ALJ awarded Smith supplemental security income (SSI). Smith received benefits until 2004 when he was found to be over the resource limit. Smith filed another SSI application in 2012, alleging additional medical conditions. The application was denied on March 26, 2014. Smith claims that he mailed a request for review on April 24, 2014. On September 21, Smith faxed a correspondence to the Social Security Administration, inquiring about the status of his appeal, with a copy of his request, dated April 24, 2014. A representative informed Smith that his request was not in the “electronic folder,” that if the Council had received the request, it would have mailed a receipt, and that his appeals request was filed as of October 1, 2014. The Council dismissed the request as untimely, finding no good cause to extend the deadline because Smith could not provide evidence that it was sent within the appropriate time. The district court determined that there was no judicial review available because the dismissal did not constitute a final decision and Smith made no colorable constitutional claims. The Sixth Circuit affirmed, rejecting arguments that Smith suffered due process violations because his request was timely submitted, different ALJs presided over his hearing and signed his decision, and the ALJ referenced the 1988 decision but failed to attach a copy as an exhibit. View "Smith v. Commissioner of Social Security" on Justia Law

The First Circuit affirmed the district court’s dismissal of Plaintiffs’ suit challenging the Social Security Administration’s (SSA) termination of tier disability benefits for lack of subject matter jurisdiction based on Plaintiffs’ failure to have exhausted their administrative remedies.After the SSA terminated the disability benefits that Plaintiffs had been receiving, Plaintiffs challenged that decision administratively. Before they had exhausted the administrative review process, however, Plaintiffs filed suit in federal court seeking various kinds of relief based presumably on the same grounds as the claims that had presented to the SSA in seeking to continue to receive their benefits. The district court granted the government’s motion to dismiss for lack of subject matter jurisdiction, concluding that Plaintiffs failed to exhaust their administrative remedies. The First Circuit affirmed, holding that Plaintiffs failed to show that they could not obtain a restoration of their benefits through the administrative review process, despite evidence suggesting that they would have a substantial chance of doing so. View "Justiniano v. Social Security Administration" on Justia Law

Minn. Stat. 125A.06(d), by its plain language, does not impose a heightened standard that burdens school districts with an absolute obligation to guarantee that each blind student will use the Braille instruction provided to attain a specific level of proficiency. I.Z.M. filed suit against the District, alleging claims under the Individuals with Disabilities Education Act (IDEA) and non-IDEA claims for relief under Title II of the Americans with Disabilities Act (ADA), and Section 504 of the Rehabilitation Act. The Eighth Circuit affirmed the district court's grant of the District's motions for judgment on the administrative record on the IDEA claim and for summary judgment on the non-IDEA claims. In this case, the ALJ cited the state regulation and expressly concluded that the District took all reasonable steps to provide instructional materials in accessible formats in a timely manner. In regard to the non-IDEA claims, the district court used the correct standard and correctly concluded that I.Z.M. failed to present evidence of bad faith or gross misjudgment View "I.Z.M. v. Rosemount-Apple Valley-Eagan Public Schools" on Justia Law

M.N. filed a due process complaint alleging that the District committed procedural and substantive violations of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400(d)(1)(A). The ALJ denied all claims and the district court affirmed. The Ninth Circuit filed an amended opinion reversing the district court's judgment, holding that neither the duration of the hearing, the ALJ's active involvement, nor the length of the ALJ's opinion can ensure that the ALJ was thorough and careful in its findings of fact; plaintiffs' claim that the District committed a procedural violation of the IDEA by failing to adequately document its offer of the visually impaired (TVI) services was not waived; the District committed two procedural violations as to the individualized education plan (IEP); the District's failure to specify the assistive technology (AT) devices that were provided infringed M.N.'s opportunity to participate in the IEP process and denied the student a free appropriate education (FAPE); the panel remanded for a determination of the prejudice the student suffered as a result of the District's failure to respond to the complaint and the award of appropriate compensation; in regard to substantive violations, the panel remanded so the district court could consider plaintiffs' claims in light of new guidance from the Supreme Court in Endrew F. v. Douglas Cty. Sch. Dist., 137 S. Ct. 988 (2017); and M.N., as the prevailing party, was entitled to attorneys' fees. View "M.C. v. Antelope Valley Union High School District" on Justia Law

The question underlying these proceedings was whether the State must consider and pay claims submitted after the effective date of the legislative deadline for pre-2006 reimbursement claims set forth in Section 61 of the 2012 amendment to the Medicaid Cap Statute, which provides that no reimbursement claims shall be made for a category of Medicaid disability expenses paid by counties to the State prior to 2006. In these appeals, the latest round in a decade-long struggle between the counties and the State over Medicaid payments, several counties challenged the constitutionality of Section 61. The Court of Appeals held (1) Section 61 is constitutional; and (2) the State is under no obligation to address outstanding county reimbursement claims filed after April 1, 2012, and the State is not required to initiate an administrative review of its records to identify and pay for any pre-2006 claims. View "County of Chemung v. Shah" on Justia Law

The focus of this appeal centered on the validity of HB 2630; 2014 Okla. Sess. Laws c. 375 (effective November 1, 2014). HB 2630 created the Retirement Freedom Act (74 O.S. Supp. 2014, sec. 935.1 et seq.), with the stated purpose as creating a new defined contribution system within the Oklahoma Public Employees Retirement System (OPERS) for persons who initially became a member of OPERS on or after November 1, 2015 (this included most state employees hired on or after this date). Plaintiffs-appellants filed a Petition for Declaratory and Supplemental Relief challenging the validity of HB 2630, claiming HB 2630 was void because it was passed by the Legislature in violation of the Oklahoma Pension Legislation Actuarial Analysis Act (OPLAA). Both parties filed a motion for summary judgment. The trial court granted defendants-appellees' motion for summary judgment and the appellants appealed. Agreeing with the trial court that the OPLAA had not been violated, the Supreme Court affirmed the grant of summary judgment in defendants' favor. View "Stevens v. Fox" on Justia Law

In response to secretly recorded videos released by the Center for Medical Progress depicting conversations with Planned Parenthood employees elsewhere, LDHH terminated PPGC Louisiana Medicaid provider agreements. PPGC and the Individual Plaintiffs filed suit against LDHH under 42 U.S.C. 1983, alleging violations of 42 U.S.C. 1396a(a)(23) and the First and Fourteenth Amendments of the U.S. Constitution. The Individual Plaintiffs, three women who are Medicaid beneficiaries and who receive medical care from one of PPGC’s Louisiana facilities, seek to continue receiving care from PPGC’s facilities. The Individual Plaintiffs contend that LDHH’s termination action will deprive them of access to the qualified and willing provider of their choice, PPGC, in violation of Medicaid’s free-choice-of-provider provision. The district court entered a preliminary injunction against LDHH’s termination of PPGC’s Medicaid provider agreements. The court held that the Individual Plaintiffs met their burden to show their entitlement to a preliminary injunction; the district court did not abuse its discretion in preliminarily enjoining LDHH’s termination of PPGC’s provider agreements; and thus the court affirmed the district court's preliminary injunction, remanding for further proceedings. View "Planned Parenthood v. Gee" on Justia Law

The Supplemental Nutrition Assistance Program (SNAP), overseen by the USDA, is administered by the states, 7 U.S.C. 2011–2036c. An individual is ineligible for SNAP benefits if he is “fleeing to avoid prosecution, or custody or confinement after conviction . . . for a crime, or attempt to commit a crime, that is a felony under the law of the place from which the individual is fleeing.” Michigan’s implementation barred assistance to anyone “subject to arrest under an outstanding warrant arising from a felony charge against that individual.” Michigan had an automated program that compared the list of public-assistance recipients with a list of outstanding felony warrants maintained by the Michigan State Police; when the program identified a match, it automatically closed the recipient’s file and generated a notice of the termination of benefits. In 2015 the Secretary of Agriculture promulgated 7 C.F.R. 273.11(n), clarifying disqualification of fugitive felons. Plaintiffs challenged Michigan's automatic disqualification and notice process. The court certified a class, held that Michigan policy violated the SNAP Act and the Constitution, and issued an injunction requiring Michigan to refrain from automatic disqualifications based solely on the existence of a felony warrant and to provide adequate notices of valid disqualification. The Sixth Circuit affirmed, rejecting claims that the plaintiffs lacked standing, of mootness, that there is no SNAP Act private right of action, and that Michigan's methods were valid. View "Barry v. Lyon" on Justia Law

Plaintiffs filed suit against the City, arguing that the City's pension reforms violate the Texas Constitution, Tex. Const. art. XVI 66(d). Two district courts ruled in favor of the City. In these consolidated appeals, the court concluded that Section 66 permits prospective changes to the pension plans of the public employees within its reach. In this case, the Pension Reform complies with Section 66 where Section 66 did not turn plaintiffs’ variable-rate cost-of-living adjustment into a one-way ratchet capable only of upward movement. The court rejected claims raised by plaintiffs of Case No. 15-10416, that only the Texas legislature has the City of Dallas v. Trammel "reserved power" to amend pension plans and thus abrogate contractual rights. The court concluded that this argument is foreclosed by Klumb v. Houston Mun. Employees Pension Sys. Finally, the court concluded that the Pension Reform does not violate the United States Constitution’s contracts clause and takings clause where neither clause create property rights and the right to public pension benefits in Texas is subject to legislative power. Accordingly, the court affirmed the district court's judgments. View "Houten, Jr. v. City of Fort Worth" on Justia Law

Plaintiff, who suffers from Ehlers-Danlos Syndrome, filed suit against the Department after it denied him "shelter needy" benefits, raising claims under 42 U.S.C. 1983; the Americans with Disabilities Act (ADA), 12 U.S.C. 12101 et seq.; and the Rehabilitation Act (RA), 29 U.S.C. 701 et seq. The court concluded that the appeal was timely, rejecting the district court's conclusion that plaintiff did not timely file notice and proof of service; concluded that the Rooker-Feldman doctrine is inapplicable to judicial review of executive action, including determinations made by a state administrative agency; and disagreed with the district court’s conclusion that section 256.045 of the Minnesota statutes prevented the court from exercising supplemental jurisdiction over the appeal from a state agency’s decision. In interpreting Minn. Stat. 256.045, subd. 7, the court concluded that subdivision 7 lays out one permissible route through which an aggrieved party may appeal from the Commissioner’s order and thus prevent it from becoming final, but it does not strip the federal court of its authority to hear the same appeal through the exercise of supplemental jurisdiction. Because the district court improperly concluded that it lacked jurisdiction based solely on the state statute, the district court failed to determine whether it should exercise supplemental jurisdiction under 28 U.S.C. 1367 or whether any abstention doctrine applied. Therefore, the court vacated the decision dismissing the supplemental state-law claim and remanded for further consideration. Because the state agency’s decision was not final, the district court erred by finding that plaintiff’s ADA and RA claims were precluded. Finally, the court agreed with the district court that plaintiff's allegations failed to state a due process or equal protection claim. Because plaintiff’s equal protection claim is predicated on the same allegations as his ADA and RA claims, the district court did not err by dismissing the section 1983 claim. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Wong v. Minnesota DHS" on Justia Law