Justia Public Benefits Opinion Summaries

Petitioner, then 45 years old and having previously worked in a factory and as a health aid, applied for disability benefits in 2004, claiming an onset date in 2004. Her conditions include peripheral vascular disease, chronic obstructive pulmonary disease, osteoarthritis, obesity, vascular dementia, depression, panic disorder, and anxiety. The Social Security Appeals Council denied review of the ALJ's adverse decision. The Seventh Circuit reversed and remanded. The ALJ failed to adequately consider petitioner's mental impairments, her obesity, and several of her physical problems. View "Arnett v. Astrue" on Justia Law

This appeal arose from the district court's order granting final judgment to the United States upon equitable claims of payment by mistake of fact and unjust enrichment against Tuomey arising out of alleged violations of the Social Security Act, 42 U.S.C. 1395nn, (the Stark Law), and awarding damages plus pre- and post-judgment interest. Because the court concluded that the district court's judgment violated Tuomey's Seventh Amendment right to a jury trial, the court vacated the judgment and remanded for further proceedings. Because the court was remanding the case, the court also addressed other issues raised on appeal that were likely to recur upon retrial. View "Drakeford v. Tuomey Healthcare System" on Justia Law

Plaintiff first sought treatment in 1988, at age 27, experiencing double vision, eye strain, and facial numbness, and was diagnosed with abducens nerve palsy of the left eye. He continued to work as a welder until 2004, when symptoms forced him to sell his business. In 2007, he applied for disability insurance benefits, alleging onset in 2004. In 2010 an ALJ rejected the claim, concluding that plaintiff; she noted plaintiff’s complaints of headaches, but concluded that they must be non-severe. The district court upheld the denial. The Seventh Circuit remanded to the Social Security Administration, holding that the ALJ’s credibility determination was not supported by substantial evidence. View "Shauger v. Astrue" on Justia Law

Alabama sued CMS claiming that it violated the federal Administrative Procedures Act (APA), 5 U.S.C. 500-596, 701-706, by issuing - without notice and an opportunity for public comment - an October 28, 2008 letter to state health officials (SHO letter). The district court held that the SHO letter constituted a substantive administrative rule issued without the notice-and-comment procedures mandated by the APA. Because the district court did not abuse its discretion in denying injunctive relief in addition to vacating the SHO letter, and because Alabama's remaining claims were unripe, the district court's judgment was affirmed. View "State of Alabama v. Centers For Medicare And Medicaid, et al." on Justia Law

This case arose when plaintiffs filed a class action complaint under 42 U.S.C. 1983, alleging that the District was violating the Medicaid Act, 42 U.S.C. 1396 et seq. Since 1993, a consent decree has governed how the District provides "early and periodic screening, diagnostic, and treatment services" under the Act. The District has now asked the district court to vacate that decree on two grounds: that an intervening Supreme Court decision has made clear that plaintiffs lack a private right of action to enforce the Medicaid Act, and that in any event, the District has come into compliance with the requirements of the Act. Because the court concluded that the district court's rejection of one of the District's two arguments did not constitute an order "refusing to dissolve [an] injunction[]" within the meaning 28 U.S.C. 1292(a)(1), the court dismissed the appeal for lack of jurisdiction. View "Salazar, et al. v. DC, et al." on Justia Law

Plaintiffs sued the Government, seeking to disclaim their legal entitlement to Medicare Part A benefits for hospitalization costs. Plaintiffs wanted to disclaim their legal entitlement to such benefits because their private insurers limited coverage for patients who were entitled to Medicare Part A benefits. Plaintiffs preferred to receive coverage from their private insurers rather than from the Government. The district court granted summary judgment for the Government because there was no statutory authority for those who were over 65 or older and receiving Social Security benefits to disclaim their legal entitlement to Medicare Part A benefits. The court understood plaintiffs' frustration with their insurance coverage. But based on the law, the court affirmed the judgment of the district court. View "Hall, et al. v. Sebelius, et al." on Justia Law

Mrs. T. was the mother of C.T., a fifteen-year-old boy with severe disabilities. At issue in this case was C.T.'s eligibility for the Department of Health and Human Services' home and community-based waiver program. C.T. was approved for the waiver program but was not receiving services under the waiver when the Department instituted a new regulation that closed the program to children but grandfathered children who were already receiving services. Mrs. T. subsequently filed a grievance with the Department seeking to have C.T. declared waiver-eligible. The Commissioner of the Department accepted the recommendation of an administrative hearing officer that denied the grievance. The superior court affirmed. Mrs. T. appealed, contending that the Department was equitably estopped from denying services because she reasonably relied to her detriment on misinformation she received that C.T. was eligible. The Supreme Court affirmed, holding that because Mrs. T. did not meet her burden to prove that her reliance on the misinformation given to her by the Department caused any detriment to C.T., the hearing officer did not err in finding that the Department was not equitably estopped from declaring C.T. ineligible for a waiver. View "Mrs. T. v. Dep't of Health & Human Servs." on Justia Law

Alohacare, a health maintenance organization (HMO), submitted a proposal to the Department of Human Services to bid for a Quest Expanded Access contract to provide healthcare services for participants in the state's Medicaid program. The Department of Human Services awarded Quest contracts to United HealthCare Insurance (United) and WellCare Health Insurance (Ohana) but not to Alohacare. Alohacare petitioned the Insurance Commissioner of the Department of Commerce and Consumer Affairs for declaratory relief that the Quest contracts required the accident and health insurers to carry an HMO license. The Commissioner concluded that the license was not required to offer the Quest managed care product because the services required under the contracts were not services that could be provided only by an HMO. The circuit court affirmed. The Supreme Court affirmed, holding (1) AlohaCare had standing to appeal the Commissioner's decision; (2) both accident and health insurers and HMOs were authorized to offer the model of care required by the Quest contracts; and (3) this holding did not nullify the Health Maintenance Organization Act. View "Alohacare v. Ito" on Justia Law

Defendant was convicted by a jury of defrauding Medicaid and Medicare of $1.4 million. On appeal, defendant argued that the evidence was insufficient; prejudicial evidence was admitted; the jury instructions were flawed; her sentencing level was erroneously increased for obstruction of justice; and the district court erred by denying her request for post-trial contact with a juror. The court affirmed the judgment because there was sufficient evidence to support the conviction and there was no reversible error. View "United States v. Delgado" on Justia Law

Organizations challenged a rule issued by the Secretary of Veterans Affairs (amending 38 C.F.R 3.304(f)) with respect to claims for service-connected disability benefits for post-traumatic stress disorder. The new rule: allows a veteran to establish PTSD without supporting evidence; applies the lower evidentiary standard only if a VA psychologist or psychiatrist, or one contracted with the VA, confirms the claimed-stressor supports the diagnosis; and defines the veteran’s "fear of hostile military or terrorist activity" as involving a response characterized by "a psychological or psycho-physiological state of fear, helplessness, or horror." The Federal Circuit upheld the rule as not violating the statutory requirement that the Secretary consider all medical evidence and give the benefit of the doubt to the claimant when there is an approximate balance of evidence. There is a rational basis for the distinction between private practitioners and VA associated practitioners. View "Nat'l Org. of Veterans' Advocates, Inc. v. Sec'y Veterans Affairs." on Justia Law