Justia Public Benefits Opinion Summaries

The issue on appeal before the Supreme Court was whether Respondent South Carolina Department of Health and Human Services and its agent, the South Carolina Department of Disabilities and Special Needs (DDSN), "properly ceased Mental Retardation/Related Disability services to" Appellant Jane Doe, a twenty-eight-year-old woman with undeniable cognitive and adaptive deficits. Based on a legal standard that the "onset of Mental Retardation must be before the age of eighteen (18) years according to accepted psychological doctrine[,]" the Hearing Officer concluded Doe was not mentally retarded. The Administrative Law Court (ALC) affirmed this legal determination, as well as the Hearing Officer's factual findings. Because the decision of the Hearing Officer and ALC was controlled by an error of law, the Supreme Court reversed and remanded the case: "DDSN could have promulgated regulations incorporating […] additional criteria as part of the definition of mental retardation. But no such steps were taken. Rather, South Carolina adopted a broad definition of mental retardation […] using language that parallels the SSI definition, and in Regulation 88-210, DDSN interpreted that definition in a manner consistent with the SSA. DDSN's interpretation of section 44-20-30 in its policy guidelines directly conflicts with Regulation 88-210 and should be disregarded." View "Doe v. South Carolina Dept. Health Human Svcs." on Justia Law

Claimant Debra Ann Luttrell appealed a district court order that affirmed the Commissioner's decision to deny her social security disability and supplemental security income benefits. Claimant challenged the Commissioner's decision on the grounds that the ALJ did not perform: (1) a proper determination at step five; (2) a proper analysis of the medical source opinions; and (3) a proper credibility determination. Finding that the ALJ's decision was free of legal error and supported by substantial evidence, the Tenth Circuit affirmed the denial of benefits. View "Luttrell v. Astrue" on Justia Law

The issue on appeal to the Tenth Circuit was whether Plaintiff Altheia Allen was disabled when her employer SouthCrest Hospital allegedly failed to accommodate her disability and terminated her employment. Because the Tenth Circuit concluded after review of the trial court record that Plaintiff failed to demonstrate a genuine issue of material fact concerning her alleged disability, the Court affirmed the district court's grant of summary judgment in favor of SouthCrest. View "Allen v. Southcrest Hospital, et al" on Justia Law

Plaintiff-Appellant Dana Franklin appealed a district court's order that affirmed the Commissioner's decision to deny her application for Social Security disability benefits. Plaintiff alleged disability based on degenerative disc disease, hypertension, rheumatoid arthritis, anxiety and depression. The agency denied her applications initially and on reconsideration. Applying the Medical-Vocational Guidelines as a framework, and and considering the testimony of a vocational expert (VE), the administrative law judge (ALJ) concluded that Plaintiff was not disabled within the meaning of the Social Security Act. The Appeals Council denied review, making the ALJ’s decision the Commissioner’s final decision. On appeal to the Tenth Circuit, Plaintiff raised two issues: (1) the ALJ erred by by failing to evaluate properly the opinions of her treating physician; and (2) the ALJ’s analysis of her credibility was contrary to law and unsupported by substantial evidence. Upon review, the Court concluded that Plaintiff failed to demonstrate reversible legal error or lack of substantial evidence in the ALJ's treating-physician analysis. Furthermore, the ALJ’s analysis of Plaintiff's credibility was supported by substantial evidence. Therefore, the Court affirmed the district court's judgment. View "Franklin v. Astrue" on Justia Law

Plaintiff-Appellee Denise Zaricor-Ritchie appealed the Commissioner's denial of disability benefits and Supplement Security Income. Plaintiff claimed she was disabled by bipolar disorder and depression. After administrative denials of her claims for benefits, she had two hearings before an ALJ, who concluded she was not disabled at step four of the five-step sequential evaluation process. Plaintiff raised three issues on appeal: (1) the ALJ erred in his treatment of the medical source evidence; (2) the ALJ erred in his credibility assessment; and (3) the ALJ failed to perform a proper analysis in concluding that she could return to her past relevant work as a dishwasher. Taking each of Plaintiff's arguments in turn, the Tenth Circuit found that the ALJ's analysis was sufficient to support its decision. The Court affirmed the Commissioner's denial of benefits. View "Zaricor-Ritchie v. Astrue" on Justia Law

Plaintiffs, Washington Medicaid beneficiaries with severe mental and physical disabilities, appealed the district court's denial of their motion for a preliminary injunction. Plaintiffs sought to enjoin the operation of a regulation promulgated by Washington's DSHS that reduced the amount of in-home "personal care services" available under the state's Medicaid plan. The court concluded that plaintiffs have demonstrated a likelihood of irreparable injury because they have shown that reduced access to personal care services would place them at serious risk of institutionalization. The court further concluded that plaintiffs have raised serious questions going to the merits of their Americans with Disabilities Act, 42 U.S.C. 12132, and Rehabilitation Act, 29 U.S.C. 794(a), claims, that the balance of hardships tipped sharply in their favor, and that a preliminary injunction would serve the public interest. Accordingly, the court remanded for entry of a preliminary injunction. View "M. R., et al. v. Dreyfus, et al." on Justia Law

The New Mexico Legislature passed House Bill 59 during the 2011 legislative session. The Bill sought to amend five different sections of the Unemployment Compensation Act in order to address an impending insolvency in the unemployment compensation fund. In addition to reducing benefits to the unemployed, House Bill 59 increased employer contributions to the unemployment compensation fund over contributions that would be made in 2011. Governor Susana Martinez partially vetoed the Bill by striking one of the variables necessary to calculate employer contributions beginning on January 1, 2012. The Petitioners, each of whom are legislators, sought a writ of mandamus to invalidate Governor Martinez's partial veto. Because the effect of the veto was to exempt most employers from making what would otherwise be mandatory contributions to the unemployment compensation fund for calendar year 2012, the Supreme Court held that the partial veto was invalid. The Court therefore issued a writ of mandamus to order that House Bill 59 be reinstated as passed by the Legislature. View "State of NM ex rel Stewart v. Martinez" on Justia Law

After developing pain in his neck and shoulders, Petitioner Gordon George was diagnosed with cancer in 2003 and underwent surgery and radiotherapy. During his recovery, he continued to experience pain spanning from his neck to his shoulder and arm. Petitioner applied for disability and supplemental security income benefits. After many and various hearings, an administrative law judge (ALJ) concluded that for the period June 1, 2003 through July 31, 2005, Petitioner was disabled during that period. But the ALJ further found that Petitioner's condition improved dramatically over time and that by August 1, 2005, he no longer met any disability listing. The Appeals Council denied review, making the ALJ's decision final. On appeal to the Tenth Circuit, Petitioner raised several challenges to the ALJ's determination that he suffered no legally cognizable disability after August 2005. Upon review, the Court rejected all those challenges, and affirmed for substantially the reasons given by the district court, with one exception. The Court found that the ALJ erred by failing to consider whether, after August 1, 2005, Petitioner suffered from a mental disability. In our case, by contrast, the ALJ has not made any factual findings "one way or the other" about the existence, severity, or functional limitations, if any, imposed by Petitioner's mental condition: "[i]t's entirely possible the ALJ on remand will find Mr. George's mental health issues have no impact on his ability to work." The Court remanded the case to the district court for further proceedings. View "George v. Astrue" on Justia Law

Plaintiff-Appellant Raymond Boswell appealed the denial of his applications for Social Security benefits. Plaintiff applied for benefits in March 2007. He alleged that he had been unable to work since December 1, 2006 because of degenerative disc disease, bone spurs, and problems with his back, neck, arms, hands, shoulders, and liver. His applications were denied at the administrative level and on reconsideration. The district court accepted the recommendation of a magistrate judge that the Commissioner’s denial of benefits be affirmed. The Tenth Circuit affirmed the Commissioner's and district court's decisions: "[Petitioner] asks this court to reweigh the evidence and substitute our judgment for that of the Commissioner. We are without the authority to do so." View "Boswell v. Astrue" on Justia Law

Medicare Part A reimburses hospitals according to a Prospective Payment System (42 U.S.C. 1395ww(d), which uses a predetermined formula to calculate reimbursement for each patient discharge without regard to the actual cost incurred. The formula includes the average hourly wage of the employees in the geographic region, including paid lunch hours. Hospitals objected to the practice because some hospitals give paid lunch breaks, which depresses the average area hourly wage and, in turn, their Medicare reimbursements. The district court granted summary judgment for the government. The Seventh Circuit affirmed, reasoning that counting all paid hours, for the sake of administrative simplicity, is not arbitrary. View "Adventist GlenOaks Hosp. v. Sebelius" on Justia Law