Justia Public Benefits Opinion Summaries

Jerry L. Blankenship applied for living miner benefits under the Black Lung Benefits Act, claiming he suffered from coal dust-induced pneumoconiosis and was totally disabled. An Administrative Law Judge (ALJ) found Blankenship entitled to a rebuttable presumption of total disability due to pneumoconiosis under 30 U.S.C. § 921(c)(4) and determined that his former employer, Island Creek Coal Company, failed to rebut this presumption. Consequently, Blankenship was awarded benefits. The Benefits Review Board affirmed the ALJ’s decision.Island Creek petitioned for review, arguing that the ALJ improperly conflated the presence of pneumoconiosis and disability causation with the separate total disability analysis. Additionally, Island Creek contended that the ALJ failed to adequately explain his decision to credit the opinions of Blankenship’s medical experts over those of Island Creek’s experts.The United States Court of Appeals for the Fourth Circuit reviewed the case and agreed with Island Creek. The court found that the ALJ improperly relied on the presence of pneumoconiosis and the causation of Blankenship’s impairment in concluding that he was totally disabled. The court also determined that the ALJ failed to provide a sufficient explanation for crediting the medical opinions of Drs. Nader and Green over those of Drs. McSharry and Sargent, violating the duty of explanation under the Administrative Procedure Act.The Fourth Circuit granted Island Creek’s petition for review, vacated the decision of the Benefits Review Board, and remanded the case with instructions for the Board to return Blankenship’s case to the ALJ for reconsideration consistent with the court’s opinion. View "Island Creek Coal Co. v. Blankenship" on Justia Law

Consuelo Griselda Nerio Mejia challenged the denial of her disability benefits by the Social Security Administration (SSA). After an administrative law judge (ALJ) denied her application, concluding that despite her severe impairments, she could perform other jobs available in the national economy, Nerio Mejia filed a civil suit. She raised three objections to the ALJ's decision, but the district court only addressed her claim that the ALJ improperly rejected her symptomology testimony, finding that the ALJ failed to provide clear and convincing reasons for doing so. The court reversed the ALJ's decision and remanded the case to the SSA for further proceedings.The United States District Court for the Central District of California found that the SSA's position was not substantially justified, making Nerio Mejia eligible for attorneys' fees under the Equal Access to Justice Act (EAJA). However, the district court reduced the fee award, excluding time spent on two additional issues that the court did not address, citing the Ninth Circuit's decision in Hardisty v. Astrue. The court concluded that fees for work on issues not decided by the court were not compensable under the EAJA.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court's order reducing the fee award. The Ninth Circuit held that the district court misapplied Hardisty, which did not address the compensability of fees for undecided issues. The appellate court found that the district court's ruling was contrary to the Supreme Court's decision in Hensley v. Eckerhart and the Ninth Circuit's en banc decision in Ibrahim v. United States Department of Homeland Security. These cases establish that a fully compensatory fee should be awarded when a plaintiff achieves excellent results, even if some issues were not decided. The Ninth Circuit remanded the case with instructions to award the full amount of fees requested by Nerio Mejia. View "MEJIA V. O'MALLEY" on Justia Law

K.M., an adult with multiple disabilities, including autism and a seizure disorder, has been receiving Medicaid-funded developmental disabilities services for over twenty years. These services, provided by Washington County Mental Health Services (WCMHS), were supposed to include more than thirty hours of community support each week. However, since March 2020, K.M. has only received two to five hours of support weekly, leading to negative health effects.K.M. petitioned the Human Services Board to order the Department of Disabilities, Aging, and Independent Living (DAIL) to provide the full services he is entitled to. The Board dismissed his petition, stating it failed to specify the action required for compliance and that an order to provide services without available staff was too vague. The Board also interpreted K.M.'s request as seeking a broader policy change, which it deemed outside its authority, citing Husrefovich v. Department of Aging & Independent Living.The Vermont Supreme Court reviewed the case and reversed the Board's dismissal. The Court held that the Board has the statutory authority to order DAIL to provide the services K.M. is entitled to under federal and state law. The Court clarified that while the Board cannot issue broad policy injunctions, it can provide specific relief to individuals. The Court found K.M.'s request for services clear and specific enough to inform DAIL of the required action. The case was remanded to the Board for further proceedings consistent with this opinion. View "In re Appeal of K.M." on Justia Law

Raymond Zaborowski, a U.S. Army veteran suffering from anxiety and PTSD, applied for Social Security disability benefits, claiming his conditions have prevented him from working since 2014. An administrative law judge (ALJ) denied his claim, stating that medical evidence indicated he could still perform light work.Zaborowski appealed to the United States District Court for the Eastern District of Pennsylvania, where he consented to jurisdiction by a magistrate judge. The magistrate judge upheld the ALJ's decision, leading Zaborowski to appeal further.The United States Court of Appeals for the Third Circuit reviewed the case. Zaborowski argued that the regulation requiring ALJs to explain their decisions violated the Social Security Act, that the ALJ failed to properly explain the supportability and consistency of medical opinions, and that the ALJ's findings were not supported by substantial evidence. The Third Circuit reviewed the legal issues de novo and the ALJ's factual findings for substantial evidence.The court held that the regulation complies with the statute, as it requires ALJs to explain the dispositive reasons for their decisions, specifically focusing on supportability and consistency. The court found that the ALJ adequately addressed these factors in her analysis, noting that the opinions of two psychologists were consistent with the record, while the treating psychiatrist's opinion was not. The court also found substantial evidence supporting the ALJ's decision, including the psychologists' opinions and evidence of Zaborowski's ability to live independently and assist his mother.The Third Circuit affirmed the decision, concluding that the ALJ's denial of benefits was supported by substantial evidence and that the regulation did not violate the Social Security Act. View "Zaborowski v. Commissioner Social Security" on Justia Law

The case involves Alam & Sarker, LLC, a convenience store in New Bedford, Massachusetts, which was disqualified from participating in the federal Supplemental Nutrition Assistance Program (SNAP) by the United States Department of Agriculture's Food and Nutrition Service (FNS). The FNS's decision was based on data indicating irregular SNAP transactions at the store, including a high number of back-to-back transactions and unusually large purchases, which suggested trafficking in SNAP benefits.The United States District Court for the District of Massachusetts granted summary judgment in favor of the FNS. The court found that the transaction data provided sufficient evidence of trafficking and that the store failed to rebut this inference with significantly probative evidence. The Market's opposition, which included customer statements and inventory records, was deemed insufficient to create a genuine issue of material fact.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the FNS's reliance on SNAP transaction data was appropriate and that the Market did not provide adequate evidence to counter the strong inference of trafficking. The court also rejected the Market's procedural due process claim, noting that the de novo hearing in the district court cured any potential procedural deficiencies at the administrative level. The court concluded that the Market received all the process that was due and upheld the permanent disqualification from SNAP. View "Alam & Sarker, LLC v. US" on Justia Law

Harold Grimes, a coal miner for 34 years, developed black lung disease and later died of lung cancer in 2018. His widow, Susan Grimes, is eligible for survivor’s benefits under the Black Lung Benefits Act. The dispute centers on whether Apogee Coal Company, Grimes’s last employer, or the Black Lung Disability Trust Fund should pay these benefits. The Department of Labor’s administrative law judge (ALJ) and the Benefits Review Board assigned financial responsibility to Apogee, with Arch Resources Inc., Apogee’s former parent corporation, bearing the liability. Arch contested this, arguing that the Trust Fund should pay.The district director initially identified Apogee as a potentially liable operator and notified Arch as Apogee’s “Insurance Carrier.” Despite Apogee’s bankruptcy in 2015, the district director and ALJ concluded that Arch, as Apogee’s self-insuring parent, was responsible for the benefits. The ALJ’s decision was based on the premise that Arch’s self-insurance umbrella covered Apogee’s liabilities. The Benefits Review Board affirmed this decision, referencing its prior cases, including Howard v. Apogee Coal Co., which supported the Department’s theory of liability for self-insuring parents.The United States Court of Appeals for the Seventh Circuit reviewed the case and found no statutory or regulatory basis for holding Arch liable for Apogee’s obligations. The court emphasized that neither the ALJ nor the Board identified a specific provision in the Act or its regulations that justified this liability. The court vacated the Board’s decision and remanded the case with instructions to assign Mrs. Grimes’s benefits to the Black Lung Disability Trust Fund. The court noted that future cases might provide additional arguments for such liability, but in this instance, the Trust Fund must pay. View "Apogee Coal Co. v. Office of Workers' Compensation Programs" on Justia Law

In 2013, Ronald Fossat, a coal miner, filed a claim for benefits under the Black Lung Benefits Act (BLBA). Fossat had worked in coal mines for 24 years, with 10 years underground and 14 years above ground. He suffered from severe respiratory issues and was on oxygen therapy. After filing his claim, he underwent medical evaluations, including those by Dr. Gagon (OWCP-sponsored) and Drs. Farney and Rosenberg (requested by his employer, Sunnyside Coal Company). The evaluations produced mixed results regarding the cause and extent of his respiratory impairment.An Administrative Law Judge (ALJ) awarded Fossat benefits in 2021, concluding that he was totally disabled based on arterial blood gas studies and medical opinions. Sunnyside appealed to the U.S. Department of Labor Benefits Review Board, which affirmed the ALJ’s decision. Sunnyside then petitioned the United States Court of Appeals for the Tenth Circuit for review, arguing that the agency’s interpretation of the BLBA was erroneous and that the ALJ’s medical merits analysis was flawed.The Tenth Circuit reviewed the case and rejected Sunnyside’s arguments. The court held that Fossat’s employment qualified him for the rebuttable presumption under the BLBA, as he had worked for more than 15 years in an underground coal mine, including above-ground work at the same mine. The court also found that the ALJ correctly applied the burden of proof and that substantial evidence supported the ALJ’s conclusion that Fossat was totally disabled. The court further determined that any error in admitting a supplemental medical report was harmless, as the ALJ’s conclusions were supportable without it. Consequently, the Tenth Circuit denied Sunnyside’s petition for review. View "Sunnyside Coal Company v. Office of Workers' Compensation Programs" on Justia Law

John Doe, a recipient of vocational rehabilitation services from the California Department of Rehabilitation, sought to have his rent covered while attending a law school outside commuting distance from his home. The Department agreed to cover his tuition and other expenses but refused to pay his rent, classifying it as a non-covered "long-term everyday living expense." Doe argued that rent should be considered "maintenance" under the Rehabilitation Act of 1973 and related California law, which the Department disputed.An administrative law judge (ALJ) upheld the Department's decision, interpreting the law to allow rent as "maintenance" only for short-term shelter, not for the three-year duration Doe required. The Superior Court of Orange County denied Doe's petition for a writ of mandate, agreeing with the ALJ that three years of rent did not qualify as "short-term shelter."The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court found that the term "maintenance" under the Rehabilitation Act and California law includes costs incurred in excess of normal expenses while receiving vocational rehabilitation services, without distinguishing between short-term and long-term costs. The court held that the Department's categorical refusal to cover long-term rent as "maintenance" was incorrect. The court reversed the lower court's decision and remanded the case, directing the Department to reconsider Doe's request for rental assistance based on his individual circumstances, rather than a blanket policy against long-term expenses. View "Doe v. Dept. of Rehabilitation" on Justia Law

James Morell, a retired research attorney for the Orange County Superior Court, was entitled to a pension under the County Employees Retirement Law of 1937 (CERL). The dispute arose over whether the $3,500 Optional Benefit Program (OBP) payments he received should be included in the calculation of his pension. The OBP allowed attorneys to allocate the $3,500 benefit to various options, including taxable cash or a healthcare reimbursement account. Morell allocated portions of the OBP to both cash and healthcare reimbursement in the years leading up to his retirement.The Superior Court of Los Angeles County initially ruled in favor of Morell, ordering the Board of Retirement for the Orange County Employees’ Retirement System (OCERS) to reconsider its decision excluding the OBP payments from Morell’s pension calculation. The court found that the board had improperly relied on a settlement agreement and a repealed statute, Government Code section 31460.1, which had excluded such payments from the definition of "compensation."The California Court of Appeal, Second Appellate District, reviewed the case. The court concluded that Resolution 90-1551, adopted by the Orange County Board of Supervisors, which excluded OBP payments from the definition of "compensation," remained valid despite the repeal of section 31460.1. The court found that Morell had elected to participate in the OBP by allocating the $3,500 benefit, and these payments reflected amounts that exceeded his salary. Therefore, the exclusion of the OBP payments from the pension calculation was proper.The Court of Appeal reversed the trial court’s judgment and remanded the case with directions to deny Morell’s petition. The court held that Resolution 90-1551 was still valid and that the OBP payments were correctly excluded from Morell’s pension calculation. View "Morell v. Board of Retirement for the Orange County Employees’ Retirement System" on Justia Law

Joshua Jones applied for disability insurance benefits (DIB) and supplemental security income (SSI) on October 1, 2019, citing various medical conditions including disc herniation, diabetes, and high blood pressure. His applications were denied initially and upon reconsideration. Jones then requested a hearing before an administrative law judge (ALJ), which took place on August 5, 2021. The ALJ denied his claims on October 6, 2021. Jones appealed to the Appeals Council, which denied review. Subsequently, he sought judicial review in the United States District Court for the Eastern District of Louisiana, which upheld the Commissioner’s decision.The district court reviewed cross-motions for summary judgment and adopted the magistrate judge’s recommendation to deny Jones’ motion and grant the Commissioner’s motion. The court found that the ALJ had applied the correct legal standards and that substantial evidence supported the decision. Jones then appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit affirmed the district court’s judgment. The court held that the ALJ correctly applied Listing 1.15, which became effective on April 2, 2021, rather than the older Listing 1.04, to evaluate Jones’ claims. The court found that applying the new listing to pending claims did not constitute impermissible retroactivity. Additionally, the court determined that the ALJ’s decision was supported by substantial evidence, including the finding that Jones did not meet the criteria for medical equivalency under Listing 1.15. The court also concluded that the ALJ properly considered the impact of Jones’ medical treatments on his ability to maintain employment, finding no evidence that his treatment regimen significantly interrupted his ability to work. View "Jones v. O'Malley" on Justia Law