Justia Public Benefits Opinion Summaries

Articles Posted in Government & Administrative Law
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The Supreme Court affirmed the decision of the district court entering summary judgment for the United States and rejecting the lawsuit brought by Appellant asking the district court to overturn the finding of the Food and Nutrition Service (FNS) of the United States Department of Agriculture that Appellant was disqualified from further participation in the supplemental nutrition assistance program (SNAP), holding that there was no error.FNS disqualified Appellant from further participation in SNAP after investigating evidence of unlawful trafficking in SNAP benefits. Thereafter, Appellant brought this action seeking to overturn the FNS's liability finding and asking the court to vacate the order of program disqualification as arbitrary and capricious. The district court entered summary judgment for the United States. The Supreme Court affirmed, holding (1) the district court did not err in entering summary judgment in favor of the United States on the liability issue; and (2) the sanction of the permanent disqualification order from the program was neither arbitrary nor capricious. View "AJ Mini Market, Inc. v. United States" on Justia Law

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Plaintiff filed in the U.S. District Court for the Western District of Washington a pro se action to challenge the denial of his claim for disability benefits by the Social Security Administration. A magistrate judge of that court, acting with the full civil authority of that court, reversed and remanded the matter to the agency for rehearing after the government conceded that there was an error in the agency’s adjudication. Plaintiff appealed that decision.   The Ninth Circuit affirmed. The panel considered whether the magistrate judge had authority to exercise the full civil jurisdiction of the district court over Plaintiff’s claim. There is no doubt that the district court had jurisdiction over the case, but Plaintiff challenged whether he had given the consent that was required for a magistrate judge to exercise that jurisdiction. The panel held that it had jurisdiction to review the antecedent question of whether the magistrate judge validly entered judgment on behalf of the district court. The panel rejected Plaintiff’s contention that, as a pro se litigant, he believed he was consenting to the magistrate judge’s issuance of a report and recommendation, not a final judgment. The panel held that Plaintiff was fully informed of the district court’s conclusion that he had knowingly and voluntarily consented to the assignment to the magistrate judge. Further, the court wrote that Plaintiff was unable to show good cause or extraordinary circumstances to withdraw consent. The panel affirmed the district court’s conclusion that Plaintiff consented to magistrate judge jurisdiction. View "VICTOR WASHINGTON V. KILOLO KIJAKAZI" on Justia Law

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The VA’s Schedule for Rating Disabilities includes diagnostic codes (DCs), each with a corresponding disability rating, 38 U.S.C. 1155. A particular veteran’s disability may not clearly fall under a delineated DC. VA regulations provide: When an unlisted condition is encountered it will be permissible to rate under a closely related disease or injury in which not only the functions affected but the anatomical localization and symptomatology are closely analogous. The VA considers the functions affected by ailments, the anatomical localization of the ailments, and the symptomatology of the ailments.Webb served in the Army, from 1968-1970, receiving an honorable discharge. Webb later developed service-connected prostate cancer, the treatment for which caused him to develop erectile dysfunction (ED). In 2015, Webb was assigned a non-compensable (zero percent) rating for his ED. The Schedule did not then include a diagnostic code for ED. The VA rated Webb’s disability by analogy to DC 7522, which provides a 20 percent disability rating for “[p]enis, deformity, with loss of erectile power.” The Board explained that DC 7522 required Webb to show “deformity of the penis with loss of erectile power.” Without such a deformity, he was not entitled to a compensable disability rating. The Veterans Court affirmed. The Federal Circuit vacated. The listed disease or injury to which a veteran’s unlisted condition is being rated by analogy must be only “closely related,” not identical. View "Webb v. McDonough" on Justia Law

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Out-of-work residents of Michigan may claim unemployment benefits if they meet certain eligibility criteria. The State’s Unemployment Insurance Agency oversees the benefits system. In 2011, with the help of private contractors, the Agency began to develop software to administer the unemployment system. The Agency sought to equip the software to auto-adjudicate as many parts of the claims process as possible. The Agency programmed software that used logic trees to help process cases and identify fraud. A claimant’s failure to return the fact-finding questionnaire, for example, led to a fraud finding, as did the claimant’s selection of certain multiple-choice responses. In August 2015, problems arose with some features of the system, prompting the Agency to turn off the auto-adjudication feature for fraud claims.Plaintiffs are four individuals who obtained unemployment benefits, which were terminated after the Agency flagged their claims for fraud. Plaintiffs filed a putative class action against three government contractors and nineteen Agency staffers, raising claims under the Fourth, Fifth, and Fourteenth Amendments, 26 U.S.C. Sec. 6402(f), and Michigan tort law. In a previous proceeding, the court held that plaintiffs’ due process rights clearly existed because they had alleged a deprivation of their property interests without adequate notice and without an opportunity for a pre-deprivation hearing.At this stage, because the remaining plaintiffs have failed to show that these procedures violate any clearly established law, the supervisors of the unemployment insurance agency are entitled to judgment as a matter of law. The court also found that an intervening plaintiff was properly prevented from joining the case, based on her untimely filing. View "Patti Cahoo v. SAS Institute, Inc." on Justia Law

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Claimant appealed the district court’s judgment upholding the denial of social security benefits by an administrative law judge (“ALJ”). Reviewing de novo the district court’s decision, Farlow v. Kijakazi, 53 F.4th 485, 487 (9th Cir. 2022), the Ninth Circuit reversed The ALJ materially mischaracterized Claimant’s functional capacity when posing a question to a vocational expert, so the vocational expert’s testimony lacked evidentiary value with respect to jobs that Claimant could perform. Here, Claimant argued that the ALJ’s question posed to the vocational expert inaccurately described her actual limitations. First, the hypothetical posed to the expert did not provide that claimant was limited to jobs with “little or no judgment.” The panel concluded that the error was harmless because the vocational expert identified only jobs with that limitation. Second, the hypothetical did not provide that Claimant could “follow short, simple instructions” only. Third, in the question posed to the vocational expert, the ALJ described a hypothetical person who “can work in an environment with occasional changes to the work setting.” The panel concluded that the ALJ materially mischaracterized Claimant’s functional capacity when posing a question to a vocational expert, so the vocational expert’s testimony lacked evidentiary value with respect to jobs that Claimant could perform. View "CAROLINE LEACH V. KILOLO KIJAKAZI" on Justia Law

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Plaintiff sought disability benefits from the Social Security Administration in 2018. He primarily based his application on pain in his lower back, hips, legs, knees, and feet, as well as on hypertension. Throughout the administrative process and upon review in federal district court, Plaintiff was denied benefits. He appealed.   The Fourth Circuit reversed and remanded the district court’s ruling affirming the ALJ’s final decision denying Plaintiff’s application for disability benefits. The court explained that nothing in the record expressly reconciles the differing mobility conclusions between 2018 and 2019, but it seems reasonable to believe that perhaps Plaintiff’s objective ailments worsened during that time, thereby impacting his mobility. To be sure, neither this Court nor an ALJ may infer a medical diagnosis—like symptom progression. But when insufficient evidence prevents an ALJ from soundly determining whether providers’ opinions are consistent, a Section 404.1520b(b)(2) inquiry by the ALJ could remedy the uncertainty with relative ease. Second, the court held that the ALJ improperly considered Plaintiff’s subjective complaints. Third, the court found that the ALJ improperly considered whether Plaintiff’s daily activities were inconsistent with his claim of disability. View "Renard Oakes v. Kilolo Kijakazi" on Justia Law

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Combs suffers from several physical and mental impairments. An ALJ found that she suffers from lumbar spondylosis, asthma, migraines/headaches, chronic pain syndrome, diabetes with diabetic polyneuropathy, obesity, attention deficit hyperactivity disorder, schizoaffective disorder, bipolar type, posttraumatic stress disorder, social anxiety disorder, generalized anxiety disorder, and borderline personality disorder. Combs sought treatment for lower back pain in March 2018 at PPG, where she received various tests, treatments, and prescriptions through 2020.Combs applied for Disability Insurance Benefits in August 2019, alleging an onset of disability on December 24, 2015. The claim was denied initially and upon reconsideration. The district court concluded the ALJ’s determination was supported by substantial evidence. The Seventh Circuit affirmed, rejecting an argument that the ALJ should have concluded that Combs suffered a closed period of disability from June 2019 to July 2020 due to her back impairment, pain, and multiple invasive procedures that would have rendered her off task or absent beyond employer tolerances. The record amply supports the ALJ’s conclusion that Combs was not disabled at any time, including during that period. View "Combs v. Kijakazi" on Justia Law

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The Supreme Court dismissed this direct appeal brought by the Iowa Department of Human Services (HDS) from a district court ruling requiring Iowa's Medicaid program to pay for sex reassignment surgery for two transgender adults and affirmed the denial of fees on cross-appeal, holding that the appeal was moot.Petitioners, adult transgender Iowans who were denied preauthorization for sex reassignment surgeries through the Medicaid program, appealed their managed care organization's denial of coverage to DHS. DHS affirmed the denials. The district court reversed, concluding that Iowa Code 216.7(3), an amendment to the Iowa Civil Rights Act (ICRA) violated the guarantee of equal protection under the Iowa Constitution. DHS appealed, but, thereafter, agreed to pay for Petitioners' surgeries. The Supreme Court dismissed the direct appeal as moot and affirmed the district court's order denying any fee award, holding that the court erred in denying Petitioners' request for attorney fees. View "Vasquez v. Iowa Dep't of Human Services" on Justia Law

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The Supreme Court reversed the judgment of the district court concluding that the Iowa Department of Human Services (DHS) was entitled to a detailed accounting and all of the residual funds The Center for Special Needs Trust Administration, Inc. had retained from Steven Muller's trust subaccount, holding that the district court erred.The Center for Special Needs Trust Administration, Inc. acted as trustee over a pooled special needs trust subaccount for the benefit of Muller. After Muller died, the Center retained all residual funds in his trust subaccount. DHS sought judicial intervention to obtain a detailed accounting of the retained funds. The district court decided in favor of DHS and ordered the Center to pay DHS all of the funds it had retained from the subaccount. The Supreme Court reversed, holding that the Center provided an adequate accounting, and therefore, the district court lacked authority to grant the relief it provided to remedy the Center's alleged failure to account for the retained funds. View "In re Medical Assistance Pooled Special Needs Trust of Steven Muller" on Justia Law

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The Supreme Court affirmed the judgment of the district court granting summary judgment for the Center for Special Needs Trust Administration, Inc., as trustee of a polled special needs trust held for the benefit of Scott Hewitt, and dismissing this action brought by the Iowa Department of Human Services (DHS) claiming it was entitled to a detailed accounting, holding that the trustee provided an adequate accounting.Title XIX of the Social Security Act required that the funds remaining in Hewitt's trust subaccount when he died must first be used to reimburse the state for its Medicaid expenditures. DHS filed a petition to invoke jurisdiction over the irrevocable trust, claiming that it was entitled to a detailed accounting to ensure that the funds retained by by the pooled special needs trust were used for a proper purpose. The district court granted summary judgment for the Center, concluding that no further accounting was required absent evidence that the Center breached its duties as trustee. The Supreme Court affirmed, holding that DHS was not entitled to relief on its claims of error. View "In re Medical Assistance Pooled Special Needs Trust Of Scott Hewitt" on Justia Law