Justia Public Benefits Opinion Summaries

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

Plaintiffs, a class of children eligible for Texas's Early and Periodic Screening, Diagnosis, and Treatment program, filed suit under 42 U.S.C. 1983 for violations of federal Medicaid law. Plaintiffs subsequently entered into a consent decree with various Texas state officials (defendants) calculated to improve implementation of the Program. In 2007, the parties agreed to a "Corrective Action Order." In 2013, defendants moved to terminate a portion of the Order and associated consent decree paragraphs under Rule 60(b)(5). The district court granted the motion and plaintiffs appealed. Determining that plaintiffs have not forfeited their appeal, the court concluded that the district court properly terminated the portion of bullet points 8-10 concerning the completion of the four assessments at issue. The court relied on certain district court decisions to interpret the proper interpretation of "shortage" - which compares the provider-to-class-member ratio with the average client load of the relevant class of provider - and concluded that the district court erred in terminating the portion of bullet points 8-10 that orders defendants to develop plans to address “shortage[s]” identified by the assessments. Accordingly, the court vacated the district court's order in part and remanded for further proceedings. The court affirmed the portion of the district court’s order terminating bullet points 6-7 and consent decree paragraph 93, and the court vacated the portion of the district court's order terminating the challenged sentence of bullet point 5. View "Frew v. Janek" on Justia Law

SEARK, operator of two hospice-care facilities, voluntarily entered into a provider agreement with the Secretary of Health and Human Services to receive Medicare reimbursement pursuant to the Medicare Act, 42 U.S.C. 1395c, 1395f(a)(7), 1395cc. The Act annually caps Medicare reimbursement. SEARK filed suit after the Secretary sent it seven demands for repayment, arguing that the cap violates the Takings Clause of the Fifth Amendment. The district court concluded that SEARK’s voluntary participation in the Medicare program precludes a takings claim. The court concluded that SEARK has not met its burden to prove the demands for repayment based on the statutory cap are a taking where the reimbursement cap allocates the government's capacity to subsidize healthcare; SEARK presented no evidence to suggest the cap makes it impossible to profitably engage in their business; and SEARK voluntarily chose to participate in the Medicare hospice program. Accordingly, the court affirmed the judgment. View "Southeast Arkansas Hospice v. Burwell" on Justia Law

In 2012, one in five female veterans and one in 100 male veterans reported that they experienced sexual abuse in the military, and an estimated 26,000 service members “experienced some form of unwanted sexual contact.” The trauma stemming from sexual abuse in the military (military sexual trauma (MST)) can result in severe chronic medical conditions, including Post-Traumatic Stress Disorder, depression, and anxiety. Generally, veterans with service-connected disabilities are entitled to disability benefits, 38 U.S.C. 1110, 1131. In response to what they viewed as the VA’s inadequate response to MST-based disability claims, veterans’ groups submitted a petition for rulemaking which requested that the VA promulgate a new regulation regarding the adjudication of certain MST-based disability claims. The Secretary of Veterans Affairs denied the petition. The Federal Circuit upheld the denial, noting its limited and deferential review and stating that the Secretary adequately explained its reasons for denying the petition. The court rejected a claim that in denying the petition, the Secretary violated the equal protection clause by intentionally discriminating against women without providing an exceedingly persuasive justification or discriminating against survivors of MST-based PTSD without providing a legitimate reason. View "Serv. Women's Action Network v. Sec'y of Veterans Affairs" on Justia Law

The Louisiana Supreme Court granted certiorari to determine whether the Sledge Jeansonne Louisiana Insurance Fraud Prevention Act, and the Louisiana Unfair Trade Practice and Consumer Protection Act, could be applied retroactively to defendant’s criminal misconduct which occurred prior to the effective dates of these statutes. Defendant Lynn Foret, a medical doctor who specialized in orthopedic surgery, pled guilty in federal court to one count of health care fraud, for criminal acts that occurred between 2003 and 2009. The trial court granted Dr. Foret’s declinatory exceptions, dismissing with prejudice, the State's action for penalties under the Sledge Jeansonne Act and dismissed with prejudice causes of action under the Louisiana Unfair Trade Practices Act. The court of appeal affirmed the trial court’s rulings, finding that the conduct regulated by the substantive statute was the underlying fraud, rather than the subsequent guilty plea. Therefore, even though the State's cause of action could not have accrued until Dr. Foret pled guilty, application of the Acts nonetheless attached new consequences to his criminal misconduct, which occurred before the Acts became effective. One judge on the appellate panel dissented, reasoning the plain language of the Sledge Jeansonne Act demonstrated it was the guilty plea that gave the State Attorney General the authority to act, not the criminal activity, and because the guilty plea was entered after the effective date of the statute, its application herein would be prospective, not retroactive. The State appealed to the Supreme Court, arguing that the Sledge Jeansonne Act was not an impermissible retroactive application of the law. After review, the Supreme Court held that both the Sledge Jeansonne Act and Louisiana Unfair Trade Practice and Consumer Protection Act operated prospectively only, applying to causes of action arising after the effective date of each Act. The Court affirmed the court ofappeal ruling finding that the statutes at issue could not be retroactively applied to this defendant’s past criminal conduct. View "Louisiana v. Foret" on Justia Law

Plaintiffs seek to represent a class of dual status National Guard technicians who had their benefits determined prior to the court's issuance of Petersen v. Astrue and would like to have their benefits readjusted to take advantage of the decision to avoid application of the Windfall Elimination Provision (WEP). The district court dismissed the complaint for lack of jurisdiction. The court affirmed the district court's decision to reject the application of mandamus jurisdiction where the district court held that there is no clear, nondiscretionary duty on behalf of the SSA to apply the Peterson decision to plaintiffs. The court also concluded that plaintiffs failed to present a colorable constitutional claim on equal protection grounds that would justify the application of the exception to 42 U.S.C. 405(g)’s jurisdictional limitations. Plaintiffs’ due process claim also does not support application of an exception to 405(g). Accordingly, the court affirmed the judgment. View "Mitchael v. Colvin" on Justia Law