Justia Public Benefits Opinion Summaries

The Maryland State Retirement System (System) filed a claim against Milliman, an actuary, asserting that Milliman had understated the contributions required to fund three of the State's ten retirement and pension systems because of Milliman's misinterpretation of a particular data code. The Retirement System Procurement Officer determined that Milliman had failed to comply with its contractual duties and awarded damages to the System. On appeal, the State Board of Contract Appeals determined that the actuary had substantially breached its contracts with the System and affirmed the damages. The circuit court affirmed the Board's findings that Milliman breached its contracts with the System and affirmed the award of lost investment earnings but reversed the Board's award of amounts equaling lost contributions. The Supreme Court granted certiorari, holding (1) Milliman was liable to the System for repeatedly misinterpreting a data code; (2) the System was not negligent in the development or transmission of data provided to Milliman and, therefore, contributory negligence did not bar the System's recovery; and (3) the circuit court erroneously reduced the Board's damage award representing lost contributions. The Court, therefore, vacated the judgment of the circuit court and affirmed the Board's decision.

The Maryland State Retirement System (System) filed a claim against Milliman, an actuary, asserting that Milliman had understated the contributions required to fund three of the State's ten retirement and pension systems because of Milliman's misinterpretation of a particular data code. The Retirement System Procurement Officer determined that Milliman had failed to comply with its contractual duties and awarded damages to the System. On appeal, the State Board of Contract Appeals determined that the actuary had substantially breached its contracts with the System and affirmed the damages. The circuit court affirmed the Board's findings that Milliman breached its contracts with the System and affirmed the award of lost investment earnings but reversed the Board's award of amounts equaling lost contributions. The Supreme Court granted certiorari, holding (1) Milliman was liable to the System for repeatedly misinterpreting a data code; (2) the System was not negligent in the development or transmission of data provided to Milliman and, therefore, contributory negligence did not bar the System's recovery; and (3) the circuit court erroneously reduced the Board's damage award representing lost contributions. The Court, therefore, vacated the judgment of the circuit court and affirmed the Board's decision.

Appellant appealed the district court's judgment upholding the Commissioner of Social Security's denial of his application for disability insurance and supplemental security income (SSI) benefits, under Title II and XVI of the Social Security Act (SSA), 42 U.S.C. 301 et seq. The court held that substantial evidence on the record supported the ALJ's finding that appellant's depression and anxiety were not severe; that the ALJ did not err in evaluating appellant's credibility; that, while the ALJ did not explicitly address the claims of appellant's girlfriend, the ALJ's error had no bearing on the outcome of appellant's case and did not require remand; and that the vocational expert's answer to a hypothetical question was not improper and constituted substantial evidence supporting the ALJ's determination. Accordingly, the court affirmed the judgment.

Plaintiff Donna Butterick appealed a district court order that affirmed the Social Security Commissioner's denial of her application for disability insurance. Plaintiff argued on appeal that the Administrative Law Judge (ALJ) committed reversible error in denying her application because he failed to follow the Commission's own procedure in examining and admitting testimony of the medical expert that testified at her hearing. Upon review of the hearing record, the Tenth Circuit concluded that the alleged procedural errors at Plaintiff's hearing were "harmless." Because Plaintiff failed to show any prejudice, the Court affirmed the ALJ's decision to deny Plaintiff disability benefits.

Plaintiff Melissa Qualls appealed a district Court's order that affirmed the Social Security Administration's decision to deny her application for disability insurance benefits. Plaintiff alleged she became disabled in 2004. Her "date last insured" was December 31, 2008, "thus she had the burden of proving that she was totally disabled on that date or before." Though Plaintiff suffered from multiple sclerosis, the Administrative Law Judge (ALJ) found that she was not disabled because "she could make a successful adjustment to other light and sedentary work that exists in significant numbers in the national economy." On appeal, Plaintiff argued that the ALJ failed to perform a proper credibility determination prior to rendering his judgment. Upon review of the Administration's record, the Tenth Circuit found that the Commissioner's decision was supported by substantial evidence, and the the law was properly applied. The Court affirmed the Commission's decision to deny Plaintiff further insurance benefits.

The former governor and former financial director of the Tribe were convicted for conspiracy to defraud the United States (18 U.S.C. 371), and of violations of 18 U.S.C. 287, 666 and 669, involving misuse of federal grant and tribal monies at the Passamaquoddy Tribe Indian Township Reservation in Maine. The First Circuit vacated the conviction of the financial director for making material misstatements about how grant money intended for HIV and substance abuse prevention was spent, but otherwise affirmed. The evidence that the director knew that his statements were false was insufficient. The district court had jurisdiction; several counts involved mismanagement of federal grants and contracts, which are subject to regulations that the Tribe is not free to ignore, and do not constitute internal tribal matters.

Plaintiff brought a Federal Tort Claims Act (FTCA), 28 U.S.C. 2671-2680, action on behalf of her minor son against the government for injuries allegedly related to his exposure to potentially dangerous, high levels of formaldehyde in their Federal Emergency Management Agency (FEMA) provided emergency housing unit (EHU). At issue was whether the district court properly dismissed plaintiff's claim for lack of subject matter jurisdiction because the claim was time-barred. The court held that neither the discovery rule, equitable estoppel, or the continuing tort doctrine applied in this case and therefore, plaintiff's FTCA claim accrued in May 2006 and her July 2008 administrative filing was untimely. Accordingly, the court affirmed the district court's dismissal of the case for lack of subject matter jurisdiction.

Plaintiff appealed from an order of the district court that reduced by two-thirds the attorney's fees award she requested for successfully appealing from the administrative denial of her application for disability benefits. The district court, attributing gaps in the administrative record to plaintiff's counsel, concluded that the alleged deficiency constituted "special circumstances" justifying a reduction in the attorney's fees awarded under the Equal Access to Justice Act, 28 U.S.C. 2412(d)(1)(A). The court held that the failure of a claimant's attorney to develop the administrative record on issues collateral to the disability determination did not constitute a "special circumstance" warranting a reduction in attorney's fees. The court also held that the district court abused its discretion in reducing the fee award based on its sua sponte critique of counsel's billing records and its conclusion that the time billed was excessive because no novel issues were raised. Accordingly, the judgment was reversed and remanded.

Appellant filed suit in the district court when the Commissioner of the Social Security Administration (SSA) denied his application for disability benefits. At issue was whether the district court had authority to permit additional evidence to be taken on remand where the SSA asked the district court to remand the case so the agency could supplement the record and the district court obliged. The court held that because the district court misunderstood the full reach of its remedial authority, the court vacated the judgment and remanded the matter to the district court to consider the issue anew.

In 2006 the claimant sought disability benefits, alleging injury in a construction accident. An ALJ denied the claim and the appeals council denied review. The district court upheld the denial. The Sixth Circuit vacated. The ALJ's decision was incomplete and improperly gave greatest weight to the opinion of a non-treating state agency physician, rather than to the opinion of a treating physician. The ALJ mischaracterized the treating physician's treatment notes.