Justia Public Benefits Opinion Summaries

Darrell Meade worked as a coal miner for 37 years and applied for benefits under the Black Lung Benefits Act, which provides compensation to miners totally disabled by pneumoconiosis. A Labor Department claims examiner initially found that Meade qualified for benefits and that Dominion Coal Corporation was responsible for payment. However, the administrative law judge reviewing the case denied the claim, concluding that Meade’s medical evidence—including x-rays, biopsies, and CT scans—did not establish the irrebuttable presumption of complicated pneumoconiosis required for benefits.Meade appealed to the Benefits Review Board. The Board agreed with the judge’s findings regarding the x-ray and biopsy evidence but determined that the judge had not sufficiently evaluated or explained his analysis of the conflicting expert opinions on the CT scans. The Board vacated the denial in part and remanded the case, instructing the judge to address the competing expert rationales and to provide a clear explanation for his findings. On remand, the judge found Dr. DePonte’s interpretation of the scans more persuasive than Dr. Adcock’s and concluded that the evidence supported a diagnosis of complicated pneumoconiosis, awarding benefits to Meade. Dominion Coal Corporation appealed, challenging both the Board’s standard of review and the judge’s authority based on alleged unconstitutional removal protections.The United States Court of Appeals for the Fourth Circuit reviewed the Board’s interlocutory and final orders. The court held that it had jurisdiction to review interlocutory Board orders after a final order was issued. It found that the Board properly remanded the case when the administrative law judge failed to adequately explain his reasoning and that substantial evidence supported the final award of benefits. The court also rejected Dominion’s constitutional challenge, holding that Dominion had not shown harm from the removal protections. The Fourth Circuit denied Dominion’s petition for review. View "Dominion Coal Corporation v. DOWCP" on Justia Law

Vernon Vanderpool worked underground for over twenty years in coal mines, primarily as a roof bolter and section foreman. After retiring due to a back injury, he developed progressively worsening respiratory symptoms and was eventually diagnosed with pneumoconiosis, commonly known as black lung disease. In 2014, Vanderpool filed a claim for benefits under the Black Lung Benefits Act, asserting that his respiratory ailments rendered him totally disabled.Following his claim, the District Director of the U.S. Department of Labor’s Office of Workers’ Compensation Programs issued a decision awarding benefits. Clinchfield Coal Company, Vanderpool’s former employer, contested this decision. An Administrative Law Judge (ALJ) held a hearing and upheld the award, finding total disability based on pulmonary function tests and medical opinion evidence. Clinchfield then appealed to the Benefits Review Board, arguing that the ALJ erred in crediting certain pulmonary function tests and in weighing medical opinions. The Board rejected these arguments and affirmed the ALJ’s decision.The United States Court of Appeals for the Fourth Circuit reviewed Clinchfield’s petition, applying a highly deferential standard to the ALJ’s findings. The court held that the ALJ properly applied regulatory standards regarding pulmonary function tests, treating deviations from quality standards as affecting the weight rather than admissibility of the evidence. The ALJ’s assessment of medical opinions, including his rationale for crediting one expert over others, was sufficiently explained and satisfied the requirements of the Administrative Procedure Act. Substantial evidence supported the finding of total disability, permitting invocation of the statutory presumption of disability under the Act. As a result, the Fourth Circuit affirmed the Board’s decision and denied Clinchfield’s petition for review. View "Clinchfield Coal Company v. DOWCP" on Justia Law

A veteran who suffered a traumatic brain injury from an improvised explosive device while deployed sought financial assistance under the Traumatic Servicemembers’ Group Life Insurance (TSGLI) program after experiencing a stroke within two years of the injury. The Army denied his claim, determining the stroke was a physical illness or disease, not a qualifying traumatic injury as defined by the relevant statute and regulations. The veteran then petitioned the Department of Veterans Affairs (VA) to amend its rules to include coverage for illnesses or diseases caused by explosive ordnance, arguing these conditions are analogous to those already covered under existing exceptions for injuries resulting from chemical, biological, or radiological weapons.The VA initially denied the rulemaking petition but agreed to further review as part of a program-wide assessment. After several years, extensive consultation with medical experts, and consideration of the petition and supporting materials, the VA issued a final denial. It concluded that expanding coverage to delayed illnesses or diseases linked to explosive ordnance would be inconsistent with TSGLI’s purpose, which focuses on immediate injuries, would deviate from the insurance model underlying the program, and could threaten its financial stability. The VA also found insufficient evidence of a direct causal relationship between explosive ordnance, traumatic brain injury, and downstream illnesses like stroke.The United States Court of Appeals for the Federal Circuit reviewed the VA’s denial under the highly deferential “arbitrary and capricious” standard of the Administrative Procedure Act. The court held that the VA provided a reasoned explanation addressing the petitioner’s arguments and the record, and did not act arbitrarily or capriciously. The petition for review was therefore denied. View "MCKINNEY v. SECRETARY OF VETERANS AFFAIRS " on Justia Law

The Missouri General Assembly enacted two statutes effective August 28, 2023: the SAFE Act, which generally prohibits health care providers from performing gender transition surgeries or prescribing cross-sex hormones and puberty-blocking drugs for minors, and the Medicaid ban, which precludes MO HealthNet payments for such treatments when used for gender transition. The statutes include specific exemptions, such as for treatment of certain medical conditions and for minors already receiving such care prior to enactment. E.N., on behalf of her minor child and joined by medical professionals and organizations, challenged both laws, alleging violations of equal protection, due process, and the gains of industry clause under the Missouri Constitution.The Circuit Court of Cole County conducted a two-week bench trial and entered judgment in favor of the State, upholding the constitutionality of both statutes. The court found the challengers had raised only facial challenges and determined that neither statute violated the constitutional provisions cited. The challengers appealed, raising multiple points of error regarding the constitutional analysis and factual findings at trial.The Supreme Court of Missouri reviewed the circuit court’s determination de novo, applying a presumption of constitutionality. Relying on recent decisions from the United States Supreme Court and the United States Court of Appeals for the Eighth Circuit, the court held that both statutes classify based only on age and medical use, not on sex or transgender status. Thus, rational-basis review applied. The court found that the statutes are rationally related to legitimate state interests, such as safeguarding minors and managing public resources, and do not infringe fundamental rights. The court affirmed the circuit court’s judgment, concluding that the challengers failed to demonstrate any constitutional violation. View "E.N. v. Kehoe" on Justia Law

James Young, a veteran who served in the military during the mid-1980s, initially filed a claim for service-connected disability benefits in 1988, alleging head injuries from an in-service car accident. The Department of Veterans Affairs (VA) regional office denied his claim in 1991, and after several years of proceedings, the Board of Veterans’ Appeals denied the claim in 1999, citing Young’s failure to appear for scheduled medical examinations. Young did not appeal the Board’s 1999 denial. Years later, in 2017, following a new claim and medical examinations, the VA granted service connection for his head injuries effective August 17, 2012.Seeking an earlier effective date linked to his original 1988 claim, Young filed a motion in 2022 with the Board to vacate its 1999 denial, alleging due process violations because the Board had failed to ensure the regional office complied with orders to search for certain records. The Board denied the motion, characterizing the alleged error as a “duty to assist error” rather than a due process error. Young appealed this denial to the United States Court of Appeals for Veterans Claims, which dismissed the appeal. The Veterans Court found that while the appeal was timely regarding the denial of the motion to vacate, such a denial was not an appealable decision under its jurisdictional statute.Upon review, the United States Court of Appeals for the Federal Circuit affirmed the Veterans Court’s dismissal. The Federal Circuit held that the Board’s denial of a motion to vacate under 38 C.F.R. § 20.1000(a), when based solely on alleged material error known at the time of the original decision, does not constitute an appealable “decision” under 38 U.S.C. § 7252. The court determined that allowing appeals from such procedural denials would undermine the statutory time bar and permit indefinite judicial review of Board decisions. View "YOUNG v. COLLINS " on Justia Law

The appellant, a Ventura County Deputy Sheriff, suffered two work-related back injuries in 2014 and 2015. Medical evaluations revealed degenerative disc disease and herniation at the L5-S1 level. Multiple physicians recommended surgical intervention, and the County authorized surgery to address his condition. However, the appellant declined the recommended procedures, citing concerns about surgical outcomes and referencing anecdotal experiences of colleagues. Later, his condition progressed, and more extensive surgery was suggested, but authorization for additional procedures was denied due to insufficient evidence. Despite ongoing pain, the appellant also declined to participate in a recommended home exercise program and a work hardening regimen.After the appellant applied for service-connected disability retirement, his application was challenged by the County and assigned to VCERA’s hearing officer for review. During the administrative hearing, the appellant testified about his refusal of surgery and physical therapy, while medical experts presented conflicting views on his prognosis and ability to return to work. The hearing officer found that the appellant had unreasonably refused recommended medical treatments with a high probability of success, and that his refusal likely worsened his condition, making him ineligible for service-connected disability retirement benefits. The Board adopted these findings and denied his application.The Superior Court of Ventura County denied the appellant’s petition for a writ of administrative mandate, concluding that his unreasonable refusal of authorized surgery and other treatments constituted valid grounds to deny benefits under the doctrine of avoidable consequences/mitigation of damages. The California Court of Appeal, Second Appellate District, Division Six, affirmed this decision. The court held that a disability retirement application may be denied if the disability is caused, continued, or aggravated by an unreasonable refusal to undergo medical treatment, even if the refused treatment is no longer effective due to the passage of time. View "Mendoza v. Bd. of Retirement of the Ventura County" on Justia Law

A longtime deputy sheriff was convicted by a federal jury of mail and wire fraud after she submitted an insurance claim for items stolen during a burglary at her home, some of which she falsely claimed as her own but actually belonged to her employer, the sheriff’s office. She also used her employer’s fax machine and cover sheet in communicating with the insurance company and misrepresented her supervisor’s identity. The criminal conduct arose after a romantic relationship with a former inmate ended badly, leading to the burglary, but the fraud conviction was based on her false insurance claim, not on the relationship or the burglary itself.Following her conviction, the California Public Employees’ Retirement System (CalPERS) determined that her crimes constituted conduct “arising out of or in the performance of her official duties” under Government Code section 7522.72, part of the Public Employees Pension Reform Act, and partially forfeited her pension. The administrative law judge and the San Francisco Superior Court both upheld CalPERS’s decision, reasoning that her actions were sufficiently connected to her employment, particularly in her misuse of employer property and resources and in the context of her relationship with the former inmate.The Court of Appeal of the State of California, First Appellate District, Division One, reversed the trial court’s judgment. The appellate court held that the statute requires a specific causal nexus between the criminal conduct and the employee’s official duties, not merely any job-related connection. The court found that the deputy’s fraudulent insurance claim, although it referenced employer property and resources, did not arise out of or in the performance of her official duties as required by the statute. Accordingly, the pension forfeiture determination was set aside. View "Myres v. Bd. of Admin. for CalPERS" on Justia Law

Christopher Thigpen applied for and received unemployment benefits from the Minnesota Department of Employment and Economic Development (DEED) for 104 weeks spanning March 2020 to March 2022. During this period, Thigpen was employed as a personal care assistant, earning weekly wages, but reported to DEED each week that he had not worked or received other income. This misrepresentation led to Thigpen receiving overpayments totaling $39,605 in standard and pandemic unemployment benefits. In April 2022, DEED reviewed his account, confirmed his employment during the relevant period, and determined that he had obtained the overpayments due to misrepresentation. As a result, DEED assessed a penalty of 40 percent of the overpaid amount, imposed 1 percent monthly interest, and barred Thigpen from receiving any future unemployment benefits until repayment, subject to a statutory ten-year cancellation period.Thigpen appealed the determination before an unemployment law judge, arguing that he did not intend to defraud DEED and misunderstood the forms. After multiple evidentiary hearings, the unemployment law judge found Thigpen’s explanations not credible, upheld the finding of misrepresentation, and applied the statutory penalty, interest, and benefit ineligibility.Thigpen requested certiorari review from the Minnesota Court of Appeals, challenging the sufficiency of evidence, burden of proof, denial of due process, and constitutionality of the penalties under the Excessive Fines Clauses of the U.S. and Minnesota Constitutions. The Court of Appeals rejected all arguments, specifically finding the penalties proportionate and comparable to those for similar offenses in Minnesota and other states.On further appeal, the Minnesota Supreme Court affirmed the Court of Appeals, holding that the penalty, interest, and benefit ineligibility for unemployment benefit misrepresentation do not violate the Excessive Fines Clauses, as they are not grossly disproportionate to the gravity of the offense and are consistent with penalties in Minnesota and other jurisdictions. View "Thigpen vs. Best Home Care LLC" on Justia Law

During the COVID-19 pandemic, full-time civil service employees working as instructors and teachers at facilities operated by the New York State Department of Corrections and Community Supervision sought unemployment benefits when their optional summer work was suspended in 2020. These employees, paid an annual salary under a collective bargaining agreement, applied for regular state unemployment benefits as well as federal pandemic-related benefits authorized by the CARES Act. Initially, their applications for benefits were granted. However, the New York State Department of Labor subsequently determined that, because the employees continued to receive their annual salary and did not meet the statutory requirements for "total unemployment" under state law, they were ineligible for both state and federal benefits, and were charged with overpayments.After hearings, Administrative Law Judges upheld the Department of Labor’s revised determinations, concluding that the claimants were not entitled to benefits due to failure to meet the "total unemployment" requirement. The Unemployment Insurance Appeal Board affirmed these decisions. On further appeal, the Appellate Division also affirmed, finding that substantial evidence supported the Board’s determination that the claimants were not "totally unemployed" during the summer in question. The court reasoned that the annual salary compensated the claimants for the entire year, including the summer, making them ineligible for unemployment benefits under state law and, consequently, ineligible for federal pandemic benefits.The New York Court of Appeals reviewed the case and held that the Department of Labor properly applied New York’s "total unemployment" requirement when evaluating eligibility for both CARES Act and related federal benefits. The court concluded that this requirement does not conflict with the CARES Act, which does not define "unemployed" or "partially unemployed" and incorporates state law for determining benefit eligibility. The court affirmed the orders of the Appellate Division. View "Klosterman v. Department of Corrections and Community Supervision" on Justia Law

Crystal Hultz, a woman born in 1987, stopped working full-time in December 2013 due to multiple health conditions, including lupus, fibromyalgia, spinal disorders, and depression. Although some of her conditions improved with treatment and surgery, she continued to experience severe, persistent symptoms of fibromyalgia, leading to fatigue and periods of being bedridden. Her daily functioning depended heavily on support from her family. Based on these ongoing symptoms, Hultz applied for Social Security disability benefits, asserting that her fibromyalgia and related health problems rendered her unable to work.Her claims for benefits were initially denied by the Social Security Administration (SSA) and again after reconsideration. Following a hearing, an Administrative Law Judge (ALJ) denied her applications, a decision upheld by the SSA's Appeals Council. Hultz sought review in the United States District Court for the District of Maryland, which remanded the case to the ALJ for further consideration of certain impairments. On remand, another ALJ again denied benefits, finding that Hultz's subjective reports of her symptoms were not fully supported by objective medical evidence. The District Court affirmed this denial.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the ALJ erred by discounting Hultz’s subjective testimony about her fibromyalgia symptoms based on a lack of objective medical evidence. The Fourth Circuit emphasized its precedent that, for conditions like fibromyalgia—which cannot be measured by objective tests—ALJs may not use the absence of such evidence to discredit claimants’ subjective accounts. The court also held that the ALJ improperly gave little weight to the opinion of Hultz’s treating physician. The Fourth Circuit reversed the denial of benefits and remanded the case for a calculation of benefits. View "Hultz v. Bisignano" on Justia Law