Justia Public Benefits Opinion Summaries

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.

This appeal involved a putative class action filed by three Pennsylvania Medicaid beneficiaries subject to the Pennsylvania Department of Public Welfare's (DPW) liens against future settlements or judgments. At issue was whether state agencies responsible for administering the Medicaid program have the authority to assert such liens and, if so, whether Pennsylvania's statutory framework was consistent with the Supreme Court's decision in Arkansas Department of Health and Human Services v. Ahlborn. The court examined the text, structure, history, and purpose of the Social Security Act, 42 U.S.C. 301 et seq., and held that liens limited to medical costs were not prohibited by the anti-lien and anti-recovery provisions of the Act, 42 U.S.C. 1396p(a)-(b). Accordingly, the court upheld Pennsylvania's longstanding practice of imposing such liens. The court also held that Pennsylvania's current statutory framework, which afforded Medicaid recipients a right of appeal from the default allocation, was a permissible default apportionment scheme.

Plaintiff Geral Brown appealed a district court's order that granted summary judgment to Defendant Hartford Insurance Company (Hartford). Plaintiff sued Hartford under the Employee Retirement Income Security Act (ERISA) for the company's termination of his long-term disability benefits. Following his injury, Plaintiff filed for Social Security Disability benefits as required by his benefit plan, and the Social Security Administration awarded him benefits. The plan then offset the monthly benefit it paid to Plaintiff by the amount of the Social Security benefit. The Hartford denied Plaintiff's administrative appeal. After examining and weighing the evidence, the trial court granted summary judgment to the Hartford. The Tenth Circuit concluded that the plan administrator's decision was supported by substantial evidence. Accordingly, the Court affirmed the decision of the district court.

Appellant Lesia Knowlton appealed the Industrial Commission's determination that she was not entitled to workers' compensation benefits. Appellant was employed as a secretary at Respondent Wood River Medical Center. In 2000, Appellant was working at her assigned station when a drain in a nearby patient's bathroom became clogged. One of the maintenance workers used a chemical cleaner to clear the drain. The chemical produced a foul odor. Workers placed fans at the doorway of the room for ventilation. The air blew past Appellant's station from morning until her shift ended in the afternoon. That night, Appellant developed a cough and body aches. Her symptoms persisted, allegedly from exposure to the chemical drain cleaner. Over the course of five years, Appellant visited multiple doctors and specialists to treat her "bronchitis-like" symptoms. Appellant filed a complaint with the Industrial Commission seeking reimbursement for her medical expenses and for temporary total disability benefits. At a Commission hearing, the referee ultimately concluded that Appellant failed to demonstrate that her medical symptoms were causally related to the chemical exposure. Although the referee determined that Appellant was not entitled to "time loss" benefits or any form of disability benefits, he did find that because the medical treatment Appellant received during the six weeks following the incident was a "reasonable precautionary step" taken in response to the exposure, she was entitled to compensation for those expenses. The Commission adopted the referee's findings of fact and conclusions of law. The Commission denied Appellant's motion for reconsideration. Subsequently Appellant appealed to the Supreme Court. The Supreme Court agreed that Appellant failed to demonstrate her medical symptoms were related to the chemical exposure. Accordingly the Court affirmed the Commission's determination.

Plaintiffs, a class of indigent children who suffered from severe emotional and mental disabilities, sued Idaho state officials more than three decades ago, alleging that the officials were providing them with inadequate care in violation of their constitutional and statutory rights. The parties reached agreements intended to remedy deficiencies in care and those agreements were embodied in three consent decrees entered and monitored by the district court. Plaintiffs appealed the 2007 order of the district court finding that defendants had substantially complied with the remaining Action Items, which were specified in an Implementation Plan that resulted from the third consent decree, asserting that it was error for the district court to apply the standard for civil contempt in determining whether to vacate the decrees. Plaintiffs further contended that the district court committed errors in fact and law in issuing protective orders barring them from taking supplemental depositions of appellee and two non-parties. The court held that the district court's application of the contempt standard with the imposition of the burden of proof on plaintiffs was error where the district court accepted the Action Items as the entire measure of compliance with the consent decree. Accordingly, the court reversed the order of the district court. The court also held that the district court committed no errors in upholding the assertion of the deliberative process privilege to one non-party and appellee, as well as the legislative privilege to the second non-party. Accordingly, the court did not abuse its discretion in issuing the protective orders.

Appellant Fairfield City Schools (Fairfield) sought reimbursement for a total disability compensation award given to one of its employees. Edward Carpenter, Jr. had hypertension since 1995. In 2002, he injured his back while at work. Mr. Carpenterâs injury resulted in a considerable amount of disability compensation. In 2008, Fairfield requested handicap reimbursement from the Ohio Bureau of Workersâ Compensation for at least part of the disability payments it made to Mr. Carpenter. Fairfieldâs application alleged that Mr. Carpenterâs pre-existing hypertension is a cardiac disease that delayed his recovery from back surgery, contributing to prolonged disability payments. The Bureau rejected Fairfieldâs application as âinsufficient to establish cardiac disease as a pre-existing condition.â Fairfield appealed the Bureauâs decision multiple times. With every appeal, Fairfield added additional doctorâs reports and Bureau datasheets to support its argument that hypertension is a cardiac disease. The court of appeals eventually denied Fairfieldâs appeal and application for a writ of mandamus. The appellate court found that the Bureau had exclusive authority to weigh the evidence Fairfield submitted, and the Bureau could find Fairfieldâs evidence insufficient to prove hypertension was a cardiac disease. Fairfield appealed to the Supreme Court, and the Court agreed with the Bureauâs and appellate courtâs decisions. The Court affirmed the lower courtâs judgment.