Justia Public Benefits Opinion Summaries

This case arose when defendant denied plaintiff's application for Medicaid benefits on the grounds that she had transferred property in 2005-2006 valued at $340,000. The district court subsequently dismissed plaintiff's 42 U.S.C. 1983 claim against defendants based on the abstention doctrine set forth in Younger v. Harris. Plaintiff appealed, contending that the district court should not have abstained from hearing her claim. Because, under Alleghany Corp. v. McCartney, abstention was appropriate in administrative proceedings like plaintiff's, the court held that the district court did not err in abstaining. View "Hudson v. Campbell, et al." on Justia Law

Plaintiff Donna Saterlee appealed a district court order that affirmed the Commissioner of Social Security's decision to deny social security disability and supplemental security income benefits. The Administrative Law Judge (ALJ) denied benefits at the last step of the five-step process for determining disability. Plaintiff argued that the ALJ erred by (1) improperly rejecting her hand impairment as medically nondeterminable at step two and consequently not including it in the RFC that formed the basis of the dispositive hypothetical to the Vocational Expert; and (2) failing to perform a proper credibility analysis in determining that complaints of limitations other than, or in excess of, those later included in the RFC were not credible. The Tenth Circuit found that the ALJ was "undeniably wrong" about the lack of documented medical evidence of Plaintiff's condition that gave rise to the alleged numbness, "undercutting the categorical rejection of such an impairment on this threshold basis." The Court remanded the case for an administrative decision that properly accounted for all of the evidence of record. View "Saterlee v. Astrue" on Justia Law

Petitioner Ellen St. Louis appealed the decision of the New Hampshire Department of Employment Security (DES) Appellate Board (board) that denied her claim for unemployment benefits. Early 2009, Petitioner received a disciplinary notice stating that her conduct was not in line with company policy because she appeared to be asleep at work and was argumentative when her trainer instructed her regarding her faulty soldering work. Subsequently, Petitioner informed a human resources representative that she was having difficulties breathing and that she was depressed. The human resources representative recommended she take medical leave. Petitioner claims that when she returned to work she could no longer perform soldering work because the fumes caused headaches, and caused her to shake, cough, and have difficulty breathing. The record indicated that she never provided Insight Technology with any medical records or doctor's instructions regarding her breathing problems or opinions regarding her inability to do soldering work. Petitioner was ultimately terminated for poor work performance. She applied for unemployment benefits but was denied. After an unsuccessful appeal to the Board, Petitioner appealed to the Supreme Court. Upon review, the Court found that the record supported the determination that Petitioner was terminated for misconduct, and that there was no error in the Board's decision. View "Appeal of Ellen St. Louis " on Justia Law

Claimant-Appellant Dennis Current appealed the Idaho Industrial Commission's denial of his unemployment benefits. Claimant argued that the Commission erred in finding he willfully made a false statement, and in failing to call one of his witnesses. The Department of Labor argued the Commission's findings were supported by substantial and competent evidence. The Supreme Court found that there was indeed substantial and competent evidence to support the Commission's findings that Claimant willfully made a false statement. The Court also found that the hearing officer did not abuse her discretion in finding that one of Claimant's witnesses would not provide relevant testimony. Accordingly, the Court affirmed the Commission's decision. View "Current v. Haddons Fencing, Inc. " on Justia Law

Plaintiff-Appellant Amby Elkins was denied social security benefits, and appealed the Commissioner's rejection of her claims. She said she suffered from degenerative disc disease, rheumatoid arthritis, tendinitis, and depression. The combination of these conditions, she argued rendered her essentially incapable of performing any work. An administrative law judge, however, rejected Plaintiff's petition. On the basis of medical evaluations by independent physicians, he concluded that Plaintiff's testimony regarding the severity of her impairments was not credible. She appealed to the district court, which affirmed the ALJ's decision. Upon review, the Tenth Circuit declined to overturn the ALJ's findings of fact, and affirmed the district court's judgment. View "Elkins v. Astrue" on Justia Law

Pro se Plaintiff-Appellant Terry Gibbs appealed a district court's order that reversed the administrative decision of the Commissioner of the Social Security Administration and remanded the case to the agency under sentence four of 42 U.S.C. 405(g). Plaintiff argued that the district court abused its discretion by remanding for further proceedings when it should have simply granted his "Motion for Judgment as a Matter of Law" and awarded him benefits. Upon review, the Tenth Circuit found that the remand was appropriate. Accordingly, the Court affirmed the district court's decision. View "Gibbs v. Astrue" on Justia Law

Plaintiff applied for Social Security disability insurance benefits and an ALJ denied the claim, noting that plaintiff failed to provide an opinion from his treating physician. When plaintiff requested review of his claim by the Appeals Council, he submitted a letter from his treating physician detailing the injuries and recommending significant restrictions on plaintiff's activity. The Appeals Council made this letter part of the record but denied plaintiff's request for review. Thus, the ALJ's decision denying benefits became the final decision of the Commissioner of the Social Security Administration. Plaintiff appealed, contending that the Appeals Council erred by failing to articulate specific findings justifying its denial of his request for review. The court rejected the argument and held that the Appeals Council need not explain its reasoning when denying review of an ALJ decision. But because in this case the court could not determine if substantial evidence supported the denial of benefits, the court reversed and remanded. View "Meyer, III v. Astrue" on Justia Law

Plaintiff-Appellant Thomas Richardson appealed a district court's order that affirmed the Commissioner of Social Security's denial of his application for Childhood Disability Benefits. Plaintiff filed two applications: one for Childhood Disability Benefits as a Disabled Adult Child and another for Supplemental Security Income benefits. Plaintiff was diagnosed with Asperger's Disorder; the examining physician opined that Plaintiff had a "fairly severe disability" such that he probably would not be able to find a job or remain employed. Both of Plaintiff's applications were initially denied. The ALJ found no evidence that Plaintiff was under a disability beginning before his twenty-second birthday, and that his impairment did not prevent him from performing unskilled work. The Commissioner affirmed the ALJ. After the Appeals Council denied review, Plaintiff filed an action in district court seeking reversal of the Commissioner’s decision denying his claim. The district court affirmed the Commissioner’s decision, and Plaintiff filed a timely appeal. On appeal, the Commissioner initially asserted that the ALJ’s findings were largely consistent with the examining physician's findings. However, upon review, the Tenth Circuit concluded that the ALJ made no such findings: the ALJ did not mention the physician's opinion "much less evaluate whether it was supported by the record." The Court remanded the case back to the ALJ to perform a proper evaluation of the physician's opinion. View "Richardson v. Astrue" on Justia Law

Plaintiff sued defendants, employees of the State of Washington's State Operated Living Alternative (SOLA) program, on behalf of herself and her daughter's estate under 42 U.S.C. 1983, alleging that defendants deprived her daughter of her Fourteenth Amendment substantive due process right to safe physical conditions while in involuntary state custody. Plaintiff subsequently appealed the district court's grant of summary judgment in favor of defendants. The court held that defendants had no constitutionally required duty of care towards plaintiff's daughter because there was no special relationship between her daughter and the state and there was no state-created danger. Therefore, the court affirmed the judgment of the district court. View "Campbell v. WA Dept. of Social and Health Services, et al." on Justia Law

Mother applied for supplemental security income on her daughter's behalf shortly before daughter's s eighteenth birthday, claiming that daughter was disabled by a combination of mental impairments (including bipolar disorder) and by physical impairments resulting from a 2005 car accident. An administrative law judge found the collective impairments severe but not disabling. The Seventh Circuit reversed and remanded. The ALJ did not properly analyze the opinion of a treating psychiatrist and did not adequately question vocational experts with respect to limitations on her concentration, pace, or persistence. View "Jelinek v. Astrue" on Justia Law