Justia Public Benefits Opinion Summaries

Appellant challenged a judgment of the district court affirming the Social Security Administration's (SSA) denial of his application for disability benefits. Appellant contended that the ALJ did not properly apply the "treating physician rule" in evaluating his application and further argued that new evidence had come to light that warranted a remand to the agency. The court held that the ALJ did not, as required by the treating physician rule, explain his reasons for rejecting the opinion of appellant's treating physician. The court also held that a letter from the Board of Medicine validating appellant's complaint, as well as a judicial determination that a physician's report contained a false representation, qualified as new evidence within the meaning of 42. U.S.C. 405(g). Therefore, the court reversed the judgment of the district court and remanded for further proceedings.

Appellant alleged that he was disabled as a result of Post Traumatic Stress Disorder, Parkinson's disease, Attention Deficit Disorder, and peripheral neuropathy and that these mental and physical limitations he had as a result of these conditions, combined with his advanced age and limited job skills, rendered him unable to perform any work available in the national economy. Appellant challenged the district court's affirmance of the Social Security Administration's (SSA) denial of his claim for disability benefits. The court affirmed the judgment and held that the ALJ's findings were supported by substantial evidence.

Plaintiff, an eleven-year-old special education student, lived in the Minnesota Independent School District No. 15 (district). An ALJ for the Minnesota Department of Education determined that the district had denied plaintiff a free appropriate public education (FAPE) within the meaning of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1482. After plaintiff filed an action in federal court seeking attorney fees and costs, both parties filed cross-motions for judgment on the administrative record. The district court reversed the ALJ's decision and denied plaintiff's motion for fees and costs and plaintiff appealed. The court affirmed the district court's judgment and held that plaintiff was not denied a FAPE where the district court did not fail to give "due weight" to the results of the administrative hearing; where the district court did not commit procedural violations of the IDEA; and where the district court did not violate the IDEA's substantive requirements.

The applicant sought disability insurance benefits and supplemental security income, claiming that she is disabled by bipolar disorder and numerous physical impairments. The Social Security Administration denied the application; a magistrate judge affirmed. The Seventh Circuit vacated and remanded. The ALJ erred in discounting the testimony of the treating physician and in finding that the applicant exaggerated her difficulties.

In 2003, Joshua Micone applied for Medicaid benefits for himself and his family. In his applications, Joshua did not report his wife Jennifer's interest in a family limited partnership. The Department of Public Health and Human Services approved Joshua's application, and the Micone family received Medicaid benefits from 2003 to 2006. Subsequently, the Department notified Joshua that his household was ineligible for benefits paid over the past three years because of Jennifer's interest in the partnership and demanded repayment. Joshua contested the demand of benefits paid. The State Board of Public Assistance upheld a hearing officer's findings that Jennifer's interest in the partnership was a countable and available resource. The district court affirmed. On appeal, the Supreme Court affirmed, holding (1) the district court correctly concluded that that the hearing officer did not violate Mont. Code Ann. 2-4-623 when he did not issue a decision within ninety days after the case was deemed submitted; and (2) the district court correctly determined that substantial credible evidence supported the Department's finding that Jennifer's interest in the partnership was an available resource.

The court agreed to rehear this case en banc to clarify under what circumstances the exhaustion requirement of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1415(l), barred non-IDEA federal or state law claims. Plaintiff, on behalf of herself and her son, appealed the district court's grant of summary judgment to defendants where the district court dismissed her claims for lack of subject matter jurisdiction because plaintiff did not initially seek relief in a due process hearing and therefore, failed to comply with one of the exhaustion-of-remedies requirement of the IDEA. The court held that the IDEA's exhaustion requirement was not jurisdictional and that plaintiff's non-IDEA federal and state-law claims were not subject to the IDEA's exhaustion requirement. Therefore, the court reversed the judgment.

Plaintiff Duane Barber (Barber) appealed the Commissioner of Social Security's denial of benefits claiming that an Administrative Law Judge (ALJ) failed to properly consider the evidence he presented in support of his claim. Plaintiff claimed he was disabled by schizophrenia, anti-social personality disorder, depression, anxiety and bipolar disorder. Barber eventually applied for Supplemental Security Income but the ALJ concluded at step five of the five-step evaluation process that Plaintiff was not disabled. The Appeals Council denied review, and a magistrate judge, acting on the parties' consent, affirmed. Plaintiff then brought his appeal to the Tenth Circuit. Upon review of the administrative record, the Tenth Circuit found that the ALJ properly explained his findings throughout. Because the record supported the ALJ's decision in this case, the Tenth Circuit affirmed the ALJ's decision to deny Plaintiff's application for benefits.

Plaintiffs, visually or manually impaired Florida citizens who were registered to vote in Duval County, Florida and were represented by the American Association of People with Disabilities, filed a putative class action against defendants, alleging that defendants violated federal statutory and state constitutional provisions by failing to provide handicapped-accessible voting machines to visually or manually impaired Florida voters after the 2000 general election. The court vacated its prior opinion and in its revised opinion, held that the district court erroneously granted plaintiffs' requested declaratory judgment and injunction against purported violations of the American with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101-12213, and the regulations promulgated thereunder. The opinion, however, based that outcome exclusively on the ground that voting machines were not "facilities" under 28 C.F.R. 35.151(b).

Plaintiffs, visually or manually impaired Florida citizens who were registered to vote in Duval County, Florida and were represented by the American Association of People with Disabilities, filed a putative class action against defendants, alleging that defendants violated federal statutory and state constitutional provisions by failing to provide handicapped-accessible voting machines to visually or manually impaired Florida voters after the 2000 general election. The court vacated its prior opinion and in its revised opinion, held that the district court erroneously granted plaintiffs' requested declaratory judgment and injunction against purported violations of the American with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101-12213, and the regulations promulgated thereunder. The opinion, however, based that outcome exclusively on the ground that voting machines were not "facilities" under 28 C.F.R. 35.151(b).

Plaintiff Rosemary Kilinski sought social security benefits in 1999. The Commissioner determined that she was disabled as of October 2003. In this case, Plaintiff appealed the district court's judgment that upheld the Commissioner's determination that her disability onset date was in 2003 rather than 1999. Upon review, the Tenth Circuit found that the Administrative Law Judge erred in assessing Plaintiff's residual functional capacity. Accordingly, the Court remanded the case for further proceedings.