Justia Public Benefits Opinion Summaries

Sean C. Flynn was laid off from his full-time job at Sun Valley Brewing Company during the COVID-19 pandemic and applied for unemployment benefits from the Idaho Department of Labor (IDOL) on March 25, 2020. Flynn received unemployment benefits from March 29, 2020, through June 27, 2020, while he was still employed part-time as a French teacher for the Community School, Inc. Flynn did not report his earnings from the Community School on the weekly certification forms required by IDOL. Additionally, when Flynn returned to full-time work at Sun Valley Brewing, he inaccurately reported his income for the week ending June 27, 2020.Flynn's claim for unemployment benefits was audited two years later, revealing discrepancies in his reported income. IDOL issued an eligibility determination letter retroactively denying Flynn's unemployment benefits and imposing civil penalties for willfully making false statements or failing to report material facts. Flynn appealed to the Idaho Department of Labor Appeals Bureau, arguing that his omissions were honest mistakes. The Appeals Examiner modified IDOL’s determination, finding Flynn misunderstood the reporting requirements for his part-time job but willfully misreported his income from Sun Valley Brewing for one week.IDOL appealed to the Idaho Industrial Commission, which conducted a de novo review and reversed the Appeals Examiner’s decision. The Commission reinstated IDOL’s original eligibility and overpayment determinations, concluding that Flynn’s omissions were willful based on the explicit instructions provided by IDOL and Flynn’s repeated failure to accurately report his income.The Supreme Court of Idaho affirmed the Commission’s decision, holding that Flynn’s omissions constituted a willful misstatement or concealment of material facts under Idaho Code section 72-1366(12). The Court determined that Flynn knew or should have known the necessity of reporting all income, and his failure to do so was intentional. Neither party was awarded attorney fees on appeal. View "Flynn v. Sun Valley Brewing Company" on Justia Law

The petitioners, current and retired Natural Resources Police Officers employed by the West Virginia Division of Natural Resources (DNR), have been receiving a statutory "subsistence allowance" since 1996. This allowance was included in their reported "compensation" to the West Virginia Consolidated Public Retirement Board (the Board) for calculating retirement annuities under the Public Employees Retirement System (PERS). In 2014, the Board discovered this inclusion was erroneous and decided to correct it by refunding overpaid contributions to active and inactive officers and adjusting retirement annuities for retired officers.The Circuit Court of Kanawha County reversed the Board's decision, finding the subsistence allowance was pensionable compensation. On appeal, the West Virginia Supreme Court held in West Virginia Consolidated Public Retirement Board v. Clark (Clark I) that the subsistence allowance was not "compensation" for PERS purposes and that the Board failed to correct the error in a timely manner for retired officers. The case was remanded for further proceedings.The Supreme Court of Appeals of West Virginia reviewed two certified questions from the Circuit Court of Kanawha County. The first question asked if the holding in Clark I required the subsistence pay received by all retired and active DNR officers to be included in calculating their pensionable income. The court answered "no," clarifying that Clark I's holding was limited to retired officers and did not apply to active and inactive officers. The second question asked if the petitioners were entitled to recover reasonable attorneys' fees from the Board. The court declined to answer, stating that it did not present an issue of law but rather a question of fact. View "Clark v. West Virginia Consolidated Public Retirement Board" on Justia Law

Two elderly individuals, Ms. Penelope Lamle and Ms. Maxine Houston, applied for Medicaid but faced delays and additional questions from the Oklahoma Department of Human Services, allegedly directed by attorney Susan Eads. They refused to answer these questions and subsequently sued, seeking an expedited decision, payment of Medicaid benefits, and damages. Both applicants died during the litigation, and their estates were substituted as parties in the appeal.The United States District Court for the Western District of Oklahoma dismissed the action with prejudice, citing the plaintiffs' failure to state a valid claim. However, the court was unaware that the applicants had died while the action was pending.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found that the claims for an injunction became moot when the agency denied benefits and the applicants died. The court noted that the requested relief would no longer benefit the estates, as the Oklahoma Department of Human Services had already denied the applications. The court also held that the Eleventh Amendment barred the requested retrospective relief. Consequently, the court remanded the case to the district court with instructions to vacate the judgment on the claim for a prospective injunction and dismiss it without prejudice.Regarding the claim against Ms. Eads in her individual capacity, the Tenth Circuit held that she was entitled to qualified immunity. The court found that the plaintiffs did not allege facts showing the violation of a clearly established right. As a result, the court affirmed the dismissal with prejudice of the claim for damages against Ms. Eads. View "Lamle v. Eads" on Justia Law

Paula S. Linden applied for Social Security benefits online in September 2014 at the age of 62, which was before her full retirement age of 66. As a result, she received smaller monthly payments than she would have if she had waited until 66. Linden claimed that she applied early based on misinformation from the Social Security Administration (SSA), which allegedly told her that she would receive the same benefits as if she had applied at 66. She sought to have her benefits recalculated as if she had applied at 66.The SSA denied her request, both initially and upon reconsideration. An Administrative Law Judge (ALJ) also ruled against her, stating that the statutory provision she cited, 42 U.S.C. § 402(j)(5), only applied to individuals who failed to apply for benefits due to misinformation. The ALJ also found insufficient evidence that Linden received misinformation from the SSA. The Appeals Council denied her request for review. Linden then filed a complaint in the United States District Court for the Eastern District of Michigan, which granted summary judgment in favor of the SSA and denied Linden’s motion for summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the plain text of 42 U.S.C. § 402(j)(5) precluded Linden’s recovery because the statute only applies to individuals who failed to apply for benefits due to misinformation. Since Linden did apply for benefits, she did not meet the statutory requirement. The court also found that the SSA’s regulations supported this interpretation. Additionally, the court noted that even if there was misinformation, it would not change the outcome because Linden did not fail to apply for benefits. Therefore, the court affirmed the district court’s decision. View "Linden v. Comm'r of Soc. Sec." on Justia Law

John Hudnall, a former financial advisor, applied for disability benefits under the Social Security Act, claiming he had been unable to work since May 1, 2015, due to major depressive disorder, anxiety, and insomnia. His application included a function report from his wife, Miyuki Sato, detailing his limitations in daily activities and self-care. Despite this, the Social Security Administration denied his application and request for reconsideration. Hudnall then sought a hearing before an Administrative Law Judge (ALJ), who also denied his claim, finding him not disabled based on medical evidence and Hudnall's self-reported activities, without explicitly addressing Sato's lay evidence.Hudnall appealed to the United States District Court for the Northern District of California, which granted summary judgment in favor of the Social Security Administration. Hudnall then appealed to the United States Court of Appeals for the Ninth Circuit.The Ninth Circuit reviewed the case and affirmed the district court's judgment. The court held that under the Social Security Administration's new regulations, effective March 27, 2017, ALJs are no longer required to provide germane reasons for discounting lay witness testimony. The court found that these regulations, which state that ALJs are not required to articulate how they considered evidence from nonmedical sources, are within the Commissioner of Social Security's broad authority and are not arbitrary and capricious. Consequently, the ALJ did not err in discounting Sato's evidence without explanation. The court resolved all other issues in a concurrently filed memorandum disposition. View "HUDNALL V. DUDEK" on Justia Law

Petitioners, veterans Joshua Bufkin and Norman Thornton, applied for service-connected PTSD disability benefits from the Department of Veterans Affairs (VA). Bufkin's claim was denied due to insufficient evidence linking his PTSD to his military service. Thornton, who already received benefits, sought an increased disability rating, which the VA denied. Both cases were reviewed de novo by the Board of Veterans’ Appeals, which upheld the VA's decisions. Bufkin and Thornton then appealed to the U.S. Court of Appeals for Veterans Claims, arguing that the evidence was in "approximate balance" and they were entitled to the benefit of the doubt.The Veterans Court affirmed the Board's decisions, finding no clear error in the approximate-balance determinations. Petitioners appealed to the Federal Circuit, challenging the Veterans Court's interpretation of 38 U.S.C. §7261(b)(1). They argued that the Veterans Court should review the entire record de novo to determine if the evidence was in approximate balance. The Federal Circuit rejected this argument and affirmed the Veterans Court's decisions.The Supreme Court of the United States reviewed the case and held that the VA's determination of whether evidence is in "approximate balance" is predominantly a factual determination, subject to clear-error review. The Court clarified that the Veterans Court must review the VA's application of the benefit-of-the-doubt rule using the same standards as other determinations: de novo for legal issues and clear error for factual issues. The judgment of the Federal Circuit was affirmed. View "Bufkin v. Collins" on Justia Law

The petitioner, Lin Luo, sought review of a final order from the Office of Administrative Hearings (OAH) that determined her ineligible for unemployment benefits from April 5, 2023, to June 28, 2023. Luo was terminated from her position at the American Chemical Society (ACS) and received post-termination payments under an Agreement and General Release. The OAH administrative law judge (ALJ) classified these payments as severance pay, which disqualified her from receiving unemployment benefits. Luo argued that the payments were settlement payments for sexual harassment claims, not severance pay.The Department of Employment Services (DOES) initially found Luo ineligible for benefits for a slightly different period. Luo appealed to OAH, where the ALJ held a hearing and excluded Luo's evidence of her harassment claims, citing the parol evidence rule. The ALJ concluded that the Agreement's language unambiguously indicated the payments were severance pay, based on Luo's years of service and lack of advance notice of termination. The ALJ also noted that the Agreement included a release of claims against ACS and found that Luo signed the Agreement without fraud, duress, or mutual mistake.The District of Columbia Court of Appeals reviewed the case and found that the ALJ erred in not considering parol evidence regarding the nature of the payments. The court noted that the parol evidence rule does not preclude evidence showing that factual recitals in an agreement are untrue. The court concluded that the ALJ should have considered Luo's testimony and evidence about her harassment claims to determine the parties' intent regarding the payments. The court vacated the OAH orders and remanded the case for further proceedings to consider this evidence. View "Luo v. District of Columbia Department of Employment Services" on Justia Law

Several unemployed workers in Alabama applied for unemployment benefits and claimed that the Alabama Department of Labor unlawfully delayed processing their claims. They sued the Alabama Secretary of Labor in state court under 42 U.S.C. §1983, arguing that the delays violated their due process and federal statutory rights. They sought a court order to expedite the processing of their claims. The Secretary moved to dismiss the complaint, arguing that the claimants had not satisfied the administrative-exhaustion requirement under Alabama law. The state trial court granted the motion and dismissed the complaint.The claimants appealed to the Alabama Supreme Court, which affirmed the dismissal on the grounds of failure to exhaust administrative remedies. The court concluded that §1983 did not preempt the state's administrative-exhaustion requirement, effectively preventing the claimants from suing to expedite the administrative process until they had completed it.The Supreme Court of the United States reviewed the case and held that state courts may not deny §1983 claims on failure-to-exhaust grounds when the application of a state exhaustion requirement effectively immunizes state officials from such claims. The Court reasoned that Alabama's exhaustion requirement, as applied, prevented claimants from challenging delays in the administrative process, thus immunizing state officials from §1983 suits. The Court reversed the Alabama Supreme Court's decision and remanded the case for further proceedings consistent with its opinion. View "Williams v. Reed" on Justia Law

Ken Lick Coal Company employed Bob Reed from 1973 to 1986, during which he was exposed to coal dust. Reed later worked for Green Valley Hydro Seeding & Reclamation and JPR, where he continued to be exposed to coal dust. Reed developed breathing problems and filed three claims for black-lung benefits. His first claim in 1986 was denied. His second claim in 2007 was initially granted but later denied by an administrative law judge who found Reed did not have pneumoconiosis. Reed's third claim in 2018 was pursued by his widow after his death.The district director awarded benefits and designated Ken Lick as the responsible operator. An administrative law judge upheld this decision, finding Reed had over 15 years of coal-mine employment, including his work with Green Valley and JPR. The judge also found that Ken Lick had stipulated to being the responsible operator during Reed's second claim, which the judge deemed binding in the third claim.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the administrative law judge erred in treating Ken Lick's prior stipulation as binding. The court found that the stipulation was a legal conclusion rather than a factual one, and thus, the judge had the authority to disregard it. The court noted that the administrative law judge would not have required Ken Lick to pay the benefits but for the stipulation. Consequently, the Sixth Circuit granted Ken Lick's petition for review and transferred the liability for Reed's claim to the Black Lung Disability Trust Fund. View "Ken Lick Coal Co. v. OWCP" on Justia Law

Dale Staten, a coal miner for nearly thirty years, retired in 2000 and passed away in January 2017 from respiratory failure after a two-week hospitalization. His widow, Bernadette Staten, filed for survivor benefits under the Black Lung Benefits Act. A Department of Labor administrative law judge (ALJ) awarded benefits, concluding that Bernadette qualified for a statutory presumption that Dale died from black lung disease due to his extensive underground mining work and total disability at the time of his death. The Benefits Review Board affirmed the ALJ's decision in a divided ruling.Consolidation Coal Company (CONSOL), Dale's former employer, challenged the ALJ's award, arguing that the 15-year presumption should only apply to chronic pulmonary conditions, not acute illnesses like Dale's respiratory failure. CONSOL contended that Dale's total disability was due to an acute condition rather than a chronic one. The ALJ had credited Dr. Sanjay Chavda's opinion that Dale was totally disabled at the time of his death, while discounting the opinions of CONSOL's experts, Dr. James Castle and Dr. Robert Farney, who argued that Dale was not disabled based on his medical history before his hospitalization.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the ALJ's award of benefits. The court held that the Black Lung Benefits Act does not require a claimant to prove that a miner's total disability arose from a chronic pulmonary condition to invoke the 15-year presumption. The court found that the ALJ acted within its authority in crediting Dr. Chavda's opinion and concluding that CONSOL failed to rebut the presumption that Dale's death was due to pneumoconiosis. The court denied CONSOL's petition for review and affirmed the judgment of the Benefits Review Board. View "Consolidation Coal Company v OWCP" on Justia Law