Justia Public Benefits Opinion Summaries

Plaintiffs had been firefighters for the city of Portland when they suffered disabling injuries. The city's charger required it to provide disability benefits to its police and fire employees who suffer injuries in the course of their employment that render them “unable to perform [their] required duties,” with a minimum disability benefit of 25 percent of the employee’s base pay, “regardless of the amount of wages earned in other employment.” The city originally determined that plaintiffs’ disabilities made them unable to perform their “required duties” and paid them disability benefits. Years later, however, the city created new job assignments that included some of the duties within the job classifications that plaintiffs had held when they were injured. Because the city gave the new job assignments the same job classifications that plaintiffs had previously held, the city maintained that plaintiffs were no longer disabled. The city therefore required plaintiffs to return to work and discontinued paying them the minimum disability benefit. Plaintiffs sued the city for breach of contract, and the circuit court granted summary judgment for the city. The Court of Appeals affirmed in part and reversed in part. After its review, the Supreme Court concluded the city charter’s use of the term “required duties” meant core duties. Because there was a genuine issue of material fact as to whether the duties of plaintiffs’ new job assignments were the “required duties” for the job classifications that plaintiffs previously held, the Court further concluded that the circuit court erred in granting summary judgment in favor of the city. View "Miller v. City of Portland" on Justia Law

To address economic conditions and projections demonstrating a severely underfunded plan, the Colorado General Assembly approved measured designed to protect present and future retirees by providing an adequately pension program. This appeal centered on changes made to the annual cost of living (COLA) that applied to increase each retiree's vested base retirement benefit. Plaintiffs in this case were retired public employees who contended that they had a contract with the State entitling each of them, upon retirement, to have their base pension benefit annually adjusted by the specific COLA formula in existence at the time they were eligible to retire, for the rest of their lives without change. The district court ruled they had no such contract right to an unchangeable COLA formula. The court of appeals disagreed, finding the retirees had a contract right to the formula in place at the time of eligibility for retirement or actual retirement based on the so-called "public policy exception," and remanded for further review to determine whether the legislature's act violated the Contract Clauses of the federal and state constitutions. The Colorado Supreme Court disagreed with the court of appeals, and agreed with the district court. The appellate court's judgment was reversed that the district court's judgment reinstated. View "Justus v. Colorado Public Employee's Retirement Association Pension Plan" on Justia Law

The issues this case presented for the Supreme Court were whether ORS 243.303(2) (which requires local governments to make available to retired employees, "insofar as and to the extent possible," the health care insurance coverage available to current officers and employees of the local government,) created a private right of action for the enforcement of that duty; or, if not, whether the Court should (under its common-law authority) provide such a right of action. The Court of Appeals held that the statute did not expressly or impliedly create a private right of action, and it considered that conclusion to be dispositive of plaintiffs' claim for relief. The Supreme Court also concluded that the statute did not expressly or impliedly create a private right of action for its enforcement. However, where a statute imposes a legal duty, but there is no indication that the legislature intended to create (or not to create) a private right of action for its enforcement, courts must (if such relief is sought) determine whether the judicial creation of a common-law right of action would be consistent with the legislative provision, appropriate for promoting its policy, and needed to ensure its effectiveness. Analyzing the duty imposed on local governments by ORS 243.303(2) under that standard, the Court declined to create an additional common-law right of action for its enforcement because: (1) plaintiffs failed to identify a cognizable common-law claim for relief whose creation is appropriate and necessary to effectuate the legislature's purpose; (2) a declaratory judgment and supplemental relief were adequate to enforce the statutory duty; and (3) a significant change in existing law would result from judicial creation of a tort claim permitting the recovery of noneconomic damages in the circumstances here, and there is no other need to create a common-law tort claim. View "Doyle v. City of Medford" on Justia Law

Beardsley was 49 years old when she fell and injured her knee. She had worked as a machine operator, assembler, inspector, and cashier. After the injury, she applied for disability insurance benefits and supplemental security income. Her doctors determined that she had meniscal tears and a ruptured ligament, compounded by obesity and worsening osteoarthritis. She declined surgery but received injections for the arthritis. Dr. Banyash examined her on behalf of the Social Security Administration and opined that pain and weakness restricted her ability to walk, stand, climb stairs, crouch, and kneel, but she was capable of sedentary work. Given Beardsley’s age and skills, a finding that she was capable of only sedentary work would have qualified her as disabled at the time under the grid SSA uses for making that determination. Another agency physician subsequently judged her able to stand or walk for about six hours of an eight-hour workday. The ALJ denied benefits, finding that she could still perform a range of light work. Beardsley argued that the ALJ gave too little weight to the opinion of the examining doctor and too much weight to an erroneous view of her daily activities, particularly care she provided for her elderly mother and that the ALJ improperly held against her the decision not to seek surgery. The district court affirmed the denial of benefits. The Seventh Circuit reversed and remanded, finding that errors undermined the “logical bridge” between evidence and conclusion.View "Beardsley v. Colvin" on Justia Law

Townsend applied for social security disability benefits and supplemental security income in 2003, at age 44, claiming that she had become incapable of full‐time gainful employment in May 2002 when she had stopped working as a result of multiple physical and psychiatric ailments, including fibromyalgia. In 2012 an ALJ decided that she had become totally disabled in November 2008. By the time that decision was rendered she had died (of pulmonary diseases apparently unrelated to the ailments alleged to have made her totally disabled). Her father was substituted for her. The district court upheld the decision. The Seventh Circuit reversed and remanded, noting multiple errors in determining the onset of total disability.View "Williams v. Colvin" on Justia Law

Plaintiffs, Medicaid beneficiaries with near total disabilities, filed suit after being denied coverage for ceiling lifts under a categorical exclusion in the state's implementing Medicaid regulations. The district court granted summary judgment for the state. The court concluded that, under binding precedent, plaintiffs have an implied private cause of action under the Supremacy Clause to pursue their challenge; the state must comply with the requirements of the Medicaid Act, 42 U.S.C. 1396 et seq., but the Act does not preempt the state's categorical exclusions; and therefore, the court affirmed the grant of summary judgment and denied the motion to vacate.View "Detgen, et al. v. Janek" on Justia Law

An ALJ denied plaintiff's application for disability insurance benefits, concluding that she was not disabled because there were jobs she could have performed during the relevant period. The Appeals Council then denied review and plaintiff appealed the Commissioner's final decision to the district court. In this appeal, the government challenged the district court's reversal of the Commissioner's decision. The court reversed and affirmed the Commissioner's final decision, concluding that the ALJ's decision was supported by substantial evidence on the record.View "Turpin v. Colvin" on Justia Law

Plaintiff appealed the district court's order denying his motion for attorney's fees under the Equal Access to Justice Act (EAJA), 28 U.S.C. 2412. The court concluded that the underlying agency action lacked a reasonable basis in law because the Social Security ALJ disregarded competent lay witness evidence on plaintiff's symptoms without comment. The court concluded that, because the ALJ disregarded competent lay witness evidence without comment, the position of the United States in the underlying action was not substantially justified. Because the government's underlying position was not substantially justified, the court awarded fees, even if the government's litigation position may have been justified. Therefore, plaintiff was entitled to an award of attorney's fees. Accordingly, the court reversed and remanded.View "Tobeler v. Colvin" on Justia Law

In 2003 the Social Security Administration denied DeLong’s applications for Disability Insurance Benefits. After each of three hearings, the ALJ concluded that DeLong was not disabled. After the third determination, the Appeals Council declined further review. In 2010, DeLong challenged the denial under 42 U.S.C. 405(g) and 1383(c)(3). The district court vacated and remanded, concluding that the ALJ had failed to provide ‘good reasons’ for the weight he gave to the opinions of treating physicians,” but rejected two other claims, noting that credibility determinations are peculiarly within the province of the ALJ, that the ALJ had not mischaracterized underlying medical evidence, and no error in the consideration of lay opinion evidence. DeLong sought attorney fees under the Equal Access to Justice Act, 28 U.S.C. 2412, contending that the denial of benefits and defense of the denial had lacked substantial justification. The district court denied the motion, reasoning that the agency’s position was substantially justified because the court had rejected all but one argument; DeLong had improperly attempted to present evidence in court that she had not presented to the ALJ; the record did not “strongly establish” entitlement to benefits; and the reversal was on procedural, not substantive, grounds. The Sixth Circuit affirmed.View "DeLong v. Comm'r of Social Sec." on Justia Law

PAMC appealed the district court's affirmance of the Secretary's decision denying PAMC its full Medicare Annual Payment Updated for the fiscal year 2009. PAMC claimed that the Department acted arbitrarily and capriciously when it refused to excuse PAMC's late filing of the required Reporting Hospital Quality Data for Annual Payment Updated (RHQDAPU) program data by the admittedly applicable deadline. The court concluded that PAMC neither pointed to any contrary or antithetical decisions by the Department under similar circumstances, nor otherwise demonstrated that the Board acted arbitrary or capriciously when it denied equitable relief. The court rejected PAMC's argument that the Board should have used the contract doctrine of substantial performance to excuse PAMC's failure to submit data at the proper time. The court did not view the Board's adherence to the policy of strict compliance with a deadline as arbitrary and capricious. Accordingly, the court affirmed the judgment of the district court.View "PAMC, LTD. v. Sebelius" on Justia Law