Justia Public Benefits Opinion Summaries

A miner who worked in West Virginia coal mines for nearly four decades applied for benefits under the Black Lung Benefits Act after retiring in 2015. From mid-2012 through December 2014, he worked for Rhino Energy, LLC as a subcontractor in mines owned by Wildcat Energy, LLC. When Rhino’s subcontract ended, he joined Wildcat’s payroll and continued working at Wildcat until his retirement in October 2015. The dispute centers on which employer—Rhino or Wildcat—should be responsible for paying his black lung benefits.After the miner filed his claim, the district director of the Office of Workers’ Compensation Programs designated Rhino as the responsible operator, finding that Wildcat had not employed the miner for the full year required by regulations and thus was not a potentially liable operator. The district director did not address Wildcat’s financial capacity, nor did he issue a Coverage Statement regarding Wildcat’s insurance status. Rhino contested its designation, arguing Wildcat should be responsible, including as a successor operator, but the district director and subsequently the Administrative Law Judge (ALJ) reaffirmed Rhino’s liability, focusing on the duration of Wildcat’s employment. The Benefits Review Board upheld the ALJ’s decision, agreeing that Wildcat had not employed the miner for a year and noting Rhino had not demonstrated Wildcat’s financial capability.The United States Court of Appeals for the Fourth Circuit reviewed the Board’s order. It held that under the correct interpretation of the regulations, Wildcat had employed the miner for the requisite year based on working days, and because the district director did not issue a Coverage Statement, Wildcat was presumed financially capable of paying benefits. The court determined Wildcat should have been designated as the responsible operator, but because regulations prohibit imposing liability on another operator at this stage, it vacated the Board’s order and remanded with instructions for the Black Lung Disability Trust Fund to pay the miner’s benefits. View "Rhino Energy, LLC v. DOWCP" on Justia Law

Michael Lincoln applied for disability insurance benefits and supplemental security income, alleging that his ability to work was limited due to conditions including prostate cancer, for which he received treatment beginning in late 2019. His treatment concluded in mid-2020, and his cancer entered remission. Lincoln continued to experience symptoms such as fatigue and reported using a cane at times, but also engaged in various daily activities. He claimed an inability to work beginning in October 2019.An administrative law judge (ALJ) held a hearing in May 2022 and, in August 2022, concluded that Lincoln was not disabled. The ALJ determined that Lincoln had the residual functional capacity to perform “light work” with certain postural limitations, and specifically found that Lincoln could perform his past work as a school bus driver. In reaching this conclusion, the ALJ found that Lincoln’s subjective complaints regarding fatigue and cane use were not entirely consistent with the medical evidence and daily activities. The ALJ also found the opinions of state agency medical consultants more persuasive than that of Lincoln’s treating nurse practitioner. The Appeals Council denied further review, making the ALJ’s decision final. The United States District Court for the Central District of Illinois affirmed the ALJ’s decision.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the ALJ’s findings, applying a deferential “substantial evidence” standard. The court held that substantial evidence supported the ALJ’s determination regarding Lincoln’s residual functional capacity, including the findings related to Lincoln’s fatigue, cane use, and the persuasiveness of medical opinions. Accordingly, the court affirmed the judgment of the district court, upholding the denial of benefits. View "Lincoln v. Bisignano" on Justia Law

A federal prisoner was sentenced in December 2020 and, due to pending charges in another jurisdiction, was held at a detention center in Rhode Island rather than being promptly transferred to his designated Bureau of Prisons (BOP) facility in South Carolina. During this period of post-sentencing detention, the prisoner claims to have participated in programs under the First Step Act (FSA), thereby accruing approximately 150 days of time credits, which could reduce his time in custody. However, the BOP did not recognize these credits because he had not undergone a formal risk and needs assessment—the BOP’s prerequisite for awarding such credits—until his eventual arrival at the designated facility in March 2022.After exhausting administrative remedies, the prisoner filed a pro se habeas petition in the United States District Court for the District of South Carolina, seeking recognition of his alleged FSA credits. The magistrate judge, without briefing or discovery, recommended dismissal. The district court adopted this recommendation, concluding that the BOP’s regulation reasonably required an initial assessment before credits could be earned, and applied Chevron deference to uphold the agency's interpretation. The district court also found no evidence the prisoner had “successfully participated” in qualifying programs before arrival at the BOP facility and dismissed the petition without prejudice, refusing to require a government response.On appeal, the United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment and remanded. The Fourth Circuit held that the case was not moot, as the prisoner could still benefit from the FSA credits if his risk status changed or a warden approved his release. The court further held that, in light of the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo, which overturned Chevron deference, the district court must independently determine whether the BOP’s interpretation of “successful participation” aligns with the best reading of the statute. View "Benson v. Warden FCI Edgefield" on Justia Law

A parent applied to a state-run program providing compensation for family members who give extraordinary care to individuals with significant medical needs. The applicant’s young child required extensive daily assistance due to chronic health issues. The Department of Health and Human Services denied the application, explaining that the child’s score on a standardized assessment, created internally by the Department, did not meet the minimum threshold to qualify for the program. The assessment assigned points based on responses to a set of questions about the child’s needs, and only those scoring at least fifty percent of possible points for their age group were deemed eligible.After the application was denied, the parent pursued an administrative appeal. The administrative law judge upheld the denial, finding that, under the Department’s rules, only the assessment score determined eligibility for “extraordinary care,” and other medical details were not considered. The Department adopted this finding in a final order and denied a rehearing. The parent then appealed to the District Court of Burleigh County, which affirmed the Department’s decision.On further appeal, the Supreme Court of North Dakota reviewed whether the Department could use the assessment and its scoring rubric to determine eligibility, even though these criteria had not been formally promulgated as administrative rules. The Court held that because these tools operated as binding eligibility requirements of general applicability, they were rules under North Dakota’s Administrative Agencies Practice Act and should have been formally adopted through the rulemaking process. The Court reversed the district court’s order and remanded the case with instructions for further proceedings consistent with its opinion. View "Ferderer v. NDDHHS" on Justia Law

A small convenience store in downtown Los Angeles, owned by an individual, participated in the Supplemental Nutrition Assistance Program (SNAP) and served many customers who used electronic benefit transfer (EBT) cards. In early 2022, the Food and Nutrition Service of the United States Department of Agriculture detected suspicious patterns in the store’s SNAP transactions. Over six months, the store processed hundreds of unusually large transactions, nearly 200 transactions that depleted a household’s monthly benefits in one day, numerous rapid consecutive transactions by the same household, and many transactions for the same dollar amount. Following a physical inspection and review of these patterns, the Agency charged the store with trafficking in SNAP benefits, meaning exchanging benefits for cash or non-eligible goods.After receiving a charge letter and providing a response that generally denied wrongdoing and offered explanations for customer behavior, the store was permanently disqualified from SNAP by the Agency. The owner and the store sought administrative review and submitted additional documents, including affidavits and receipts, but the Agency upheld its decision. The plaintiffs then filed for judicial review in the United States District Court for the Central District of California. The government moved for summary judgment, and the plaintiffs relied on much of the same evidence previously submitted. The district court granted summary judgment for the government, finding that the plaintiffs failed to raise a genuine dispute of material fact as to whether trafficking had occurred.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s grant of summary judgment de novo. The court held that the government’s evidence established suspicious transaction patterns supporting an inference of SNAP trafficking and that the plaintiffs failed to provide sufficient evidence to create a genuine dispute as to the legitimacy of the flagged transactions. The Ninth Circuit affirmed the district court’s grant of summary judgment in favor of the government. View "BROTHERS MARKET LLC NO. 2 V. USA" on Justia Law

An employee worked for Cowin & Company for nearly three decades, performing construction in coal mines and regularly being exposed to coal dust. Years after his employment ended, he filed a claim for benefits under the Black Lung Benefits Act, alleging total disability due to pneumoconiosis (“black lung disease”) caused by his coal mine work. The claimant relied on a regulatory presumption that applies to miners who have a disabling breathing impairment and at least fifteen years of qualifying coal mine employment. A key dispute in the case involved how to calculate a “year” of coal mine employment under Department of Labor regulations.An administrative law judge initially granted benefits, finding the claimant had at least fifteen years of qualifying employment, thus triggering the presumption. Cowin & Company appealed to the Benefits Review Board, which vacated the benefits award in part and instructed the judge to recalculate the length of coal mine employment, questioning the method used to credit years of employment. On remand, the judge again found more than fifteen years, but the Board disagreed with the method, holding that a claimant must prove both a 365/366-day period of employment and at least 125 working days during that period. Ultimately, after further proceedings, the administrative law judge found only 13.76 years of qualifying employment, and the Board affirmed the denial of benefits.The United States Court of Appeals for the Eleventh Circuit reviewed the Board’s decision. The court held that, under the plain text of the relevant regulation, a claimant establishes a “year” of coal mine employment by showing at least 125 working days in or around coal mines during a calendar year or partial periods totaling one year. The court granted the petition for review, vacated the Board’s decision, and remanded for further proceedings. View "Hayes v. Director, OWCP" on Justia Law

A miner filed a claim for benefits under the Black Lung Benefits Act, asserting total disability due to lung disease following over two decades of coal mine employment. The miner had a significant history of cigarette smoking, but no evidence of clinical pneumoconiosis was present. The dispute centered on whether his disabling pulmonary impairment—despite his smoking history—was legally attributable to his coal mine dust exposure.An Administrative Law Judge (ALJ) first reviewed the claim and found that the miner had worked in coal mines for 27 years and suffered from a totally disabling pulmonary impairment. These facts entitled the miner to a statutory presumption that his disability was caused by pneumoconiosis. The ALJ determined that the mining company, as the responsible employer, failed to rebut this presumption. The ALJ discredited the employer’s medical experts, who attributed the impairment solely to smoking, because their opinions did not properly consider the additive effects of smoking and coal dust, as recognized by the Department of Labor’s Preamble to its Black Lung regulations. The Benefits Review Board affirmed the ALJ’s decision.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the ALJ correctly applied the law by requiring the employer to rebut the presumption, and properly evaluated the medical evidence in light of the regulatory guidance. The court found that the ALJ’s decision was supported by substantial evidence and that there was no legal error in the treatment of expert opinions or the regulatory preamble. The Fourth Circuit denied the mining company’s petition for review, leaving the award of benefits to the miner in place. View "Wolf Run Mining Company v. DOWCP" on Justia Law

William Walls was found by an Illinois state court to be a sexually violent person in 2015, leading to his civil commitment under Illinois law. The commitment was based, in part, on statements he made or that were made by his treatment providers while he was incarcerated for a prior sexual assault conviction. Walls has argued that these statements were obtained in violation of his constitutional rights. After his commitment, his case involved extensive delays, including a twelve-year period before the initial commitment decision and seven years before the state appellate court resolved the appeal filed by his counsel.After the 2015 commitment order, Walls—sometimes proceeding pro se despite being represented—filed a series of appeals and petitions. The Illinois Appellate Court eventually affirmed both the 2015 and a subsequent 2018 recommitment decision in a consolidated opinion. Walls’s first federal habeas petition under 28 U.S.C. §2254 was dismissed by the United States District Court for the Central District of Illinois on procedural default grounds. He did not appeal that dismissal. After the 2018 recommitment proceeding, Walls filed a second federal habeas petition, which was dismissed as an unauthorized successive petition under 28 U.S.C. §2244(b) because it challenged the same 2015 order or did not raise new claims as required.The United States Court of Appeals for the Seventh Circuit reviewed Walls’s appeal of the district court’s dismissal. The court held that, to the extent Walls was once again contesting the 2015 commitment order, his petition was barred as a successive habeas application. Alternatively, if he was challenging later decisions, he had failed to raise or exhaust federal claims relating to those decisions. The Seventh Circuit affirmed the district court’s dismissal of Walls’s petition. View "Walls v Posey" on Justia Law

The case concerns significant changes made by the U.S. Department of Housing and Urban Development (HUD) to the Continuum of Care (CoC) program, which provides federal funding for homeless assistance projects. In November 2025, HUD issued a new Notice of Funding Opportunity (NOFO) that rescinded a previously issued two-year NOFO and introduced new requirements, including a drastic reduction in renewal funding for core permanent housing projects and new eligibility conditions. These changes threatened to eliminate funding for many projects, risking increased homelessness in the affected communities. Two groups of plaintiffs, including states, cities, and advocacy organizations, challenged HUD’s actions, alleging violations of the Administrative Procedure Act (APA) and constitutional provisions.The United States District Court for the District of Rhode Island issued preliminary injunctions prohibiting HUD from rescinding the prior NOFO and from implementing the challenged conditions in the new NOFOs. The court found that HUD’s actions likely violated the APA, were arbitrary and capricious, and would cause irreparable harm by creating funding gaps and service disruptions for vulnerable populations. After Congress passed new appropriations legislation in early 2026—setting a structure for grant renewals to avoid funding gaps—HUD moved to dissolve the injunctions, arguing that the legislative changes eliminated any ongoing harm and affected the merits of the legal claims. The district court denied the motion, concluding that the risk of harm persisted and that the plaintiffs remained likely to succeed on their claims.On appeal, the United States Court of Appeals for the First Circuit reviewed only the district court’s denial of HUD’s motion to dissolve the preliminary injunctions. The court held that HUD failed to make a strong showing that the intervening appropriations law eliminated the plaintiffs’ risk of harm or undermined the basis for the injunctions. The First Circuit therefore denied HUD’s request for a stay pending appeal. View "National Alliance to End Homelessness v. Department of Housing and Urban Development" on Justia Law

The United States brought a lawsuit against Florida alleging that the state was discriminating against children with medically complex conditions by failing to provide care in the most integrated setting as required under Title II of the Americans with Disabilities Act (ADA). The federal government claimed that Florida’s inadequate provision of at-home and group-home care forced some children into institutionalization and placed others at serious risk of institutionalization. Additionally, it argued that once children were institutionalized, Florida’s poor care coordination and deficient transition planning made it difficult for families to bring their children home.This litigation proceeded over many years, culminating in a bench trial in the United States District Court for the Southern District of Florida. Previously, the United States Court of Appeals for the Eleventh Circuit had determined that the United States had statutory authority to sue Florida under the ADA. After trial, the district court found that Florida’s Medicaid program failed to provide adequate private duty nursing (PDN) services and effective care coordination, resulting in unnecessary institutionalization of children or placing them at risk. The district court concluded that these failures constituted violations of the ADA as interpreted by Olmstead v. L.C. ex rel Zimring, and issued a permanent injunction requiring Florida to improve its services, with specific mandates regarding PDN, care coordination, transition planning, data collection, and appointment of a monitor.On appeal to the United States Court of Appeals for the Eleventh Circuit, Florida challenged the findings and scope of the injunction. The Eleventh Circuit held that the United States may seek injunctive relief for systemic ADA violations affecting a group of children, not just those who individually filed complaints. The court affirmed the district court’s findings that the United States established the elements required under Olmstead, that the violations were widespread, and that system-wide injunctive relief was warranted. The Eleventh Circuit affirmed the district court’s liability determinations and most provisions of the injunction, but vacated or modified some portions as overbroad. View "United States v. Florida" on Justia Law