Justia Public Benefits Opinion Summaries

The case involves Keeley Hamilton, who applied for disability insurance benefits and supplemental security income from the Social Security Administration (SSA) due to her physical impairments. An administrative law judge (ALJ) within the SSA denied her applications, concluding that despite her physical impairments, she could still work in two occupations. Hamilton appealed, arguing that she should be considered disabled unless she could work in at least three occupations, a rule she derived from Ninth Circuit caselaw.Hamilton's applications were initially denied by an ALJ, who found that she could still work in two occupations despite her physical impairments. The district court remanded the case back to the SSA for further proceedings, citing a failure to ask the vocational expert about potential conflicts between his testimony and the occupational information in the Dictionary of Occupational Titles. On remand, the ALJ held another hearing and again denied Hamilton's applications, concluding that Hamilton's skills permitted her to perform two semi-skilled sedentary occupations: food checker and auction clerk.In the United States Court of Appeals for the Sixth Circuit, Hamilton argued that the ALJ should have found her disabled because his findings showed that her skills did not transfer to at least three occupations. The court disagreed with Hamilton's interpretation of the rule, stating that the ALJ did not err by ruling that Hamilton was not disabled under the regulations because she had skills that transferred to a significant range of work. The court affirmed the district court's decision upholding the Social Security Administration's denial of benefits to Hamilton. View "Hamilton v. Comm'r of Soc. Sec." on Justia Law

Lonnie Reidburn, a self-employed insurance agent, appealed a decision by the South Dakota Department of Labor, Reemployment Assistance Division (Department) that he must repay $24,690 in pandemic unemployment benefits he received. Reidburn's income was based on commissions he received for new policies and renewals, which required in-person visits to clients' homes or businesses. During the COVID-19 pandemic, Reidburn experienced a significant reduction in his ability to procure new policies and renewals because clients did not want him to make in-person visits. As a result, Reidburn's income decreased. He applied for Pandemic Unemployment Assistance (PUA) through the Department and received benefits for 39 weeks. However, the Department later determined that Reidburn's loss of income was not the direct result of the pandemic and issued a determination of ineligibility.The administrative law judge (ALJ) upheld the Department's determination of ineligibility, reasoning that the individual decisions of Reidburn's clients to preclude him from entering their homes or places of business were not a direct result of the pandemic. However, the ALJ rejected the Department's at-fault determination and found that Reidburn was not at fault for the overpayment. The ALJ also concluded that Reidburn's request for a waiver was untimely. Reidburn appealed the ALJ's decision to the circuit court, which affirmed the ALJ's decision.The Supreme Court of the State of South Dakota reversed the ALJ's determination that Reidburn was ineligible to receive PUA benefits for 35 of the 39 weeks at issue, based on its recent decision in Bracken v. South Dakota Department of Labor and Regulation, Reemployment Assistance Division. The court declined to address the Department's argument that Reidburn failed to present sufficient evidence to support his testimony that he experienced a significant reduction in services, as the Department did not raise this argument at Reidburn's administrative hearing. The court affirmed the circuit court's denial of Reidburn's motion for attorney fees. View "Reidburn v. Department of Labor & Regulation" on Justia Law

The case revolves around Brenda Warnell, who applied for disability insurance benefits and supplemental security income under the Social Security Act in 2019. Warnell claimed she was unable to work due to debilitating migraines and chronic pain in her back, shoulders, and neck. Her medical record was mixed, with some physicians assessing her as having severely limited functional capacity, while others found her capable of limited physical exertion.The Administrative Law Judge (ALJ) denied Warnell's claim, finding that the medical evidence did not substantiate the severity of her alleged functional limitations. The ALJ concluded that Warnell's pain symptoms did not prevent her from performing light work with moderate noise and limited physical requirements. The ALJ's decision was affirmed by the district court.In the United States Court of Appeals for the Seventh Circuit, Warnell challenged the ALJ's decision, arguing that the ALJ needed to provide more detailed accounts of the medical evidence. The court rejected this argument, stating that the ALJ's decision was supported by substantial evidence and met the light standard set by the Supreme Court. The court found that the ALJ had provided a sufficient explanation for her decision, highlighting specific evidence that contradicted Warnell's claims and addressing conflicting evidence. The court affirmed the ALJ's decision, rejecting Warnell's claim that the ALJ needed to provide more detailed accounts of the medical evidence. View "Warnell v. O'Malley" on Justia Law

The plaintiff, Robert Conway, appealed a decision by the district court that upheld the denial of his social security benefits by an administrative law judge (ALJ). The ALJ had found that Conway could perform "medium work" based on the testimony of a vocational expert. Under Terry v. Saul, the term "medium work" was presumed to imply a six-hour standing and walking limitation.However, Conway argued that this presumption was rebutted during the cross-examination of the vocational expert. When asked if someone could perform medium work if they were only able to be on their feet for six hours maximum, the expert responded that the three sample occupations provided would not be possible and it would be difficult to provide substitute unskilled, medium occupations.The United States Court of Appeals for the Ninth Circuit agreed with Conway, finding that the vocational expert's significantly different responses revealed that the expert did not understand the ALJ’s hypothetical to impliedly include a six-hour standing and walking limitation. As such, the expert’s response to the ALJ’s question had no evidentiary value to support the ALJ’s finding that Conway could perform jobs in the national economy. The court concluded that the error was not harmless and reversed the district court’s judgment, remanding the case to the Commissioner of Social Security for further proceedings. View "CONWAY V. O'MALLEY" on Justia Law

In this appeal before the United States Court of Appeals for the Seventh Circuit, the plaintiff, Kelly Chavez, had been denied supplemental security income due to her various mental and physical impairments. The administrative law judge (ALJ) at a hearing found that Chavez could perform jobs that existed in significant numbers in the economy. This decision was affirmed by the district court, leading to this appeal. Chavez contended that the vocational expert's testimony, which the ALJ relied on, did not provide substantial evidence supporting the ALJ's decision.The vocational expert, Sarah Holmes, testified that a person with Chavez's age, background, and ability could perform several light exertion jobs, such as cleaner, office helper, and storage rental clerk. She used a software program, Job Browser Pro, to estimate the number of jobs, which uses data from the Bureau of Labor Statistics.Chavez's main argument was that Holmes did not explain Job Browser Pro's underlying formula, thereby rendering her testimony unreliable. However, the court held that Holmes's testimony provided substantial evidence for the ALJ's finding. The court highlighted that Holmes used a generally accepted source of job numbers, provided a straightforward overview of how the source worked, offered to provide additional information about the source's underlying formula, and identified jobs commonly found in the national economy. Therefore, the court affirmed the district court's judgment. View "Chavez v. O'Malley" on Justia Law

The plaintiff, Todd Hess, applied for supplemental security income, disability insurance benefits, and disabled adult child benefits, all of which are administered by the Social Security Administration. While his claims for supplemental security income and disability insurance benefits were approved, his claim for disabled adult child benefits was denied. To qualify for disabled adult child benefits, Hess had to prove that he had a disability that continued uninterrupted from before his 22nd birthday until the filing of his application for benefits. He claimed that his depression, panic disorder, obsessive-compulsive disorder, and other impairments made him disabled during that entire period. However, after two hearings, an Administrative Law Judge disagreed, concluding that Hess was disabled as of June 9, 2009, but not before then. The ALJ's decision was based on gaps in Hess's treatment history, notes from his physicians, and occasional work he performed as an independent contractor. The Appeals Council did not assume jurisdiction, and the district court found that the ALJ's decision was supported by substantial evidence. The United States Court of Appeals for the Seventh Circuit agreed and affirmed the judgment of the district court. View "Hess v. O'Malley" on Justia Law

In the case before the Court of Appeal of the State of California First Appellate District Division Two, the appellant, Debra Abney, challenged the decision of the State Department of Health Care Services and the City and County of San Francisco to consider money garnished from her Social Security payments as income for the purposes of determining her eligibility for benefits under Medi-Cal.Abney's Social Security payments were being reduced by nearly $600 each month to satisfy a debt she owed to the IRS. The authorities considered this garnished money as income, which led to Abney being ineligible to receive Medi-Cal benefits without contributing a share of cost. Abney argued that the money being garnished was not income “actually available to meet her needs” under the regulations implementing the Medi-Cal program.The trial court rejected Abney's argument, and she appealed. The Court of Appeal affirmed the trial court's decision. The Court of Appeal held that the tax garnishment was "actually available" to meet Abney's needs because it benefitted her financially by helping to extinguish her debt to the IRS. Therefore, the garnished money was correctly considered as income for the purpose of calculating her eligibility for the Medi-Cal program. View "Abney v. State Dept. of Health Care Services" on Justia Law

This case arose from an appeal against the grant of summary judgment by a district court on a claim related to disability benefits. The appellant, Emily Seago, had contended that Nancy Berryhill was unlawfully serving as the acting Social Security Commissioner in July 2018 when she ratified the appointment of the Administrative Law Judge who later denied Seago’s claim.The United States Court of Appeals for the Fifth Circuit rejected Seago's argument and affirmed the district court’s grant of summary judgment. The court held that Berryhill was lawfully serving as Acting SSA Commissioner under 5 U.S.C. § 3346(a)(2) when she ratified the appointments of all SSA Administrative Law Judges in July 2018.The court noted that 5 U.S.C. § 3346(a) provides for two independent periods of acting service, during the 210-day period following a vacancy, and for the duration of a nomination's pendency in the Senate. The court found that these periods can operate independently, as indicated by the use of the word "or" to separate the two subsections. The court noted that the statutory text does not suggest that service under one subsection excludes someone from also serving under the other.The court also found that this interpretation aligned with the statutory purpose, providing an incentive for the President to submit timely nominations without denying vital public services to the American people due to delays in the Senate confirmation process. View "Seago v. O'Malley" on Justia Law

The United States Court of Appeals for the Ninth Circuit affirmed the decision of the district court, which upheld the Commissioner of Social Security's denial of a claimant's application for supplemental security income. The claimant argued that the Social Security Administration's 2017 revised regulations for evaluating medical opinions were partially invalid because they did not provide a reasoned explanation for permitting an administrative law judge to avoid articulating how he or she accounts for the "examining relationship" or "specialization" factors under the Social Security Act or the Administrative Procedure Act (“APA”). The court found that the Commissioner's decision to promulgate the 2017 medical evidence regulations fell within his wide latitude to make rules and regulations, particularly those governing the nature and extent of the proofs and evidence to establish the right to benefits. The court also joined the Eleventh Circuit in holding that the regulations were valid under the APA, as the agency's response to public comment and reasoned explanation for the regulatory changes established that the regulations were not arbitrary or capricious. View "CROSS V. O'MALLEY" on Justia Law

Erik Bertaud, who suffered serious injuries when a tree branch fell on his head, applied for disability insurance benefits and supplemental security income from the Social Security Administration. His application was denied, and he appealed. The Appeals Council remanded the case twice, but after the third denial, Bertaud's request for review was denied, making the ALJ's decision the final decision of the Commissioner. Bertaud then sought judicial review, arguing that the ALJ had failed to develop the record of his disability, pointing to over 800 pages of new medical evidence. The district court denied Bertaud's motion for summary judgment and affirmed the Commissioner's decision, and Bertaud appealed to the United States Court of Appeals for the Seventh Circuit.The court held that although an ALJ has a duty to develop a full and fair record, this duty is limited when the claimant is represented by an attorney. The claimant's duty to submit evidence is ongoing and covers any additional related evidence they become aware of. The court noted that Bertaud was represented and his attorney had confirmed that the evidence was complete and supplemented the record when necessary. Therefore, the court concluded that the ALJ did not fail to develop Bertaud's medical record. The court affirmed the district court's decision denying Bertaud's motion for summary judgment and affirming the decision of the Commissioner. View "Bertaud v. O'Malley" on Justia Law