Justia Public Benefits Opinion Summaries

A group of Black farmers and their association, along with several individual members, sought to file claims with the U.S. Department of Agriculture (USDA) for financial assistance under a program created by the Inflation Reduction Act of 2022. They wished to submit applications on behalf of deceased relatives who had allegedly experienced discrimination in USDA farm lending programs. The USDA, however, had a policy that excluded applications reporting only discrimination against individuals who were deceased at the time of application, making such claims ineligible for the program.The plaintiffs filed suit in the United States District Court for the Western District of Tennessee, seeking an injunction to require the USDA to accept these “legacy claims.” The district court denied their motion for a preliminary injunction and granted the government’s motion to dismiss under Rule 12(b)(6), holding that the relevant statute only authorized financial assistance to living farmers. The plaintiffs appealed this decision to the United States Court of Appeals for the Sixth Circuit and also sought an emergency injunction pending appeal, which was denied.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The appellate court held that the statutory language of § 22007(e) of the Inflation Reduction Act required the USDA to provide “assistance” to farmers who experienced discrimination, and that “assistance” was forward-looking and could not be provided to deceased individuals. The court found that the statute did not authorize compensation for past harm to deceased farmers, distinguishing “assistance” from “compensation.” The court affirmed the district court’s judgment and denied the motion for an injunction pending appeal as moot, holding that the USDA was required to reject applications filed on behalf of deceased farmers. View "Black Farmers & Agriculturalists Ass'n v. Rollins" on Justia Law

Claudette Rabdeau sought disability benefits under the Social Security Act, claiming that her cervical spine disorder, severe headaches, and mental impairments rendered her unable to work since June 2014. Medical records showed that while Rabdeau experienced significant pain and frequent headaches beginning in 2014, her symptoms were generally well-managed through medication and treatments, including Botox injections, until May 2018, when her condition worsened and became disabling.Rabdeau’s initial application for benefits was denied by an Administrative Law Judge (ALJ) in 2018, who found she could still work during the relevant period. After a remand from the Social Security Administration Appeals Council for further consideration of her migraines and mental impairments, the same ALJ issued a partially favorable decision in 2019, finding Rabdeau disabled only from May 9, 2018 onward. Rabdeau appealed the unfavorable portion, and the Appeals Council remanded the case again in 2021, citing insufficient evaluation of evidence regarding her headaches prior to May 2018. On remand, a different ALJ reviewed the case and, after considering testimony from a new vocational expert, denied benefits for the period before May 2018, finding her impairments were not severe enough to be disabling. The United States District Court for the Eastern District of Wisconsin affirmed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s affirmance, applying the “substantial evidence” standard. The court held that the second ALJ was not required to address the prior ALJ’s findings as long as the decision was supported by substantial evidence. The Seventh Circuit found that the medical record supported the ALJ’s conclusion and affirmed the denial of benefits for the period before May 2018. View "Rabdeau v. Bisignano" on Justia Law

Horace Meredith worked as a coal miner for several decades, with his last employment at Hobet Mining, Inc. During Meredith’s tenure at Hobet, Arch Coal Company, Inc. was Hobet’s parent company and provided self-insurance for black lung liabilities. Years after Meredith left Hobet and after Arch had sold Hobet to Magnum Coal (which was later acquired by Patriot Coal Company), Meredith filed a claim for black lung benefits. By the time of his claim, both Patriot and Hobet were defunct, and the Department of Labor sought to hold Arch liable for Meredith’s benefits, despite Arch no longer owning or insuring Hobet.After Meredith filed his claim, the district director designated Hobet as the responsible operator and Arch as the insurance carrier. Arch and Hobet contested this designation, arguing that Arch was no longer responsible for Hobet’s liabilities and that the Black Lung Disability Trust Fund should cover the claim. The Administrative Law Judge (ALJ) found Hobet to be the responsible operator and Arch liable as its self-insurer at the time of Meredith’s last employment. The Department of Labor’s Benefits Review Board affirmed the ALJ’s decision, holding Hobet and Arch liable for the claim.The United States Court of Appeals for the Fourth Circuit reviewed the Board’s decision. The court held that neither the Black Lung Benefits Act nor its regulations imposed liability on Arch under these circumstances. Specifically, the court found that Hobet did not meet the regulatory requirements to be a financially capable responsible operator, and Arch could not be held liable as a self-insurer for claims filed long after it ceased to own or insure Hobet. The Fourth Circuit granted the petition for review, vacated the Board’s decision, and remanded for further proceedings consistent with its opinion. View "Hobet Mining, Inc. v. Director, Office of Workers' Compensation Programs" on Justia Law

The defendant, who had been receiving disability insurance benefits due to a medical diagnosis, operated a jewelry business while collecting these benefits. The Social Security Administration (SSA) began investigating after suspecting that the defendant was earning income that could affect his eligibility. The SSA asked the defendant whether he had worked or received income since his diagnosis, to which he responded negatively. However, evidence showed that he had significant gross income from jewelry sales, and the SSA determined that his countable income likely exceeded regulatory caps, making him ineligible for benefits. The defendant was subsequently charged with taking government property and making false statements.The United States District Court for the District of New Mexico presided over the trial. The government presented evidence of substantial gross income and efforts by the defendant to conceal earnings. The defendant did not provide information about business expenses that could have reduced his countable income. The jury convicted him on multiple counts related to theft of government property and false statements. At sentencing, the district court calculated the loss amount, including benefits paid to the defendant’s children and payments made outside the charged period, resulting in a 15-month prison sentence.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the evidence was sufficient for a reasonable jury to find that the defendant’s countable income exceeded the regulatory caps, even without detailed expense information, given the high gross income and lack of contrary evidence. The court also found no reversible error in the jury instructions, as the defendant failed to timely challenge the district court’s reasoning. Regarding sentencing, the court held that it was proper to include reasonably foreseeable payments to the defendant’s children and payments outside the charged period in the loss calculation. Any error in including Medicare premiums was deemed harmless. The convictions and sentence were affirmed. View "United States v. Sandoval" on Justia Law

A tenant entered into a lease for an apartment in Minneapolis that was subsidized under the Section 8 project-based voucher program, with the local public housing authority paying most or all of the rent directly to the landlord. After the tenant fell behind on utility payments, her electricity was disconnected, and she and her boyfriend broke into the building’s utility closet to restore power, inadvertently affecting other units. The landlord learned of this breach but continued to accept three months of rental payments from the public housing authority on the tenant’s behalf. Later, the landlord filed an eviction action based on the tenant’s breach of the lease.The Hennepin County District Court dismissed the tenant’s counterclaim regarding the utility shutoff and, following the Minnesota Court of Appeals’ decision in Westminster Corp. v. Anderson, held that the common law doctrine of waiver by acceptance of rent did not apply to rental payments made by a public housing agency. The district court found the tenant had materially breached the lease and did not address her retaliation defense. The Minnesota Court of Appeals affirmed the district court’s rulings on the waiver and breach issues but remanded for consideration of the retaliation defense.The Minnesota Supreme Court reviewed only the waiver issue. It overruled Westminster, holding that the common law rule—whereby a landlord who accepts rent with knowledge of a tenant’s breach waives the right to evict for that breach—applies equally to private and publicly subsidized tenancies. The court clarified that whether a landlord has accepted rent for purposes of this doctrine is a factual question, to be determined by the totality of the circumstances, including the landlord’s conduct after payment. The Supreme Court reversed the court of appeals and remanded for further proceedings. View "Hook & Ladder Apartments, L.P. v. Nalewaja" on Justia Law

The defendant was cited for a third offense of driving under the influence (DUI) and for driving with a suspended license, both misdemeanors, in November 2021. He was initially convicted in Justice Court and then sought a trial de novo in the District Court. At trial, a jury found him guilty of both offenses. During sentencing, the defendant’s counsel informed the court that the defendant was on a limited income, receiving disability and social security, and requested that the court consider his financial situation when imposing fines and fees, including a request to waive the public defender fee.After the jury verdict in the Twenty-First Judicial District Court, the court sentenced the defendant to jail time, most of which was suspended, and imposed a $3,000 fine with statutory surcharges and a $250 public defender fee. The written judgment also included a $10 technology fee and $50 in prosecution costs, which were not mentioned in the oral pronouncement. The defendant appealed, arguing that the written judgment conflicted with the oral sentence and that the court failed to consider his ability to pay the fines and fees.The Supreme Court of the State of Montana reviewed the case. It held that when there is a conflict between the oral sentence and the written judgment, the oral sentence controls, and thus the $10 technology fee and $50 prosecution costs should not have been included. The court further held that the District Court erred by failing to inquire into the defendant’s ability to pay the public defender fee, the $3,000 fine, and the statutory surcharges, as required by Montana statutes. The Supreme Court reversed the sentence and remanded the case for a new sentencing hearing consistent with its opinion. View "State v. Post" on Justia Law

The case concerns the fatal shooting of Brett Ness in Billings, Montana, following a series of drug-related disputes. Alexander Garrett LaForge III, along with several others, was involved in confrontations with Ness over an alleged shortfall in a methamphetamine transaction. After escalating tensions and threats, LaForge and a group of associates returned to Ness’s trailer, where LaForge shot Ness in the head with a .45 caliber pistol. Ness died later that day. Multiple co-defendants received plea deals in exchange for their testimony against LaForge.The Thirteenth Judicial District Court, Yellowstone County, presided over LaForge’s trial. LaForge requested a substitution of counsel shortly before trial, citing communication issues and dissatisfaction with his attorney’s preparation. The District Court conducted an inquiry and denied the request, finding no substantial breakdown in communication. During trial, LaForge also requested a cautionary jury instruction regarding the credibility of co-defendants’ testimony, which the District Court declined, instead providing standard witness credibility instructions and a specific instruction regarding one co-defendant’s accountability. The jury convicted LaForge of deliberate homicide. At sentencing, the court ordered LaForge to pay $72,000 in restitution to the victim’s mother for lost business income, based on her testimony about canceled jobs following her son’s death.The Supreme Court of the State of Montana reviewed the case. It held that the District Court did not abuse its discretion in denying LaForge’s request for substitute counsel or in its jury instructions regarding co-defendant testimony. However, the Supreme Court found that the $72,000 restitution award was not supported by sufficient evidence and that the record was unclear as to whether the victim’s mother, as a business representative, qualified as a “victim” under the restitution statutes. The Supreme Court affirmed the conviction and other aspects of the judgment, reversed the restitution award, and remanded for a new hearing to determine the proper amount and recipient of restitution. View "State v. LaForge" on Justia Law

A group of plaintiffs filed suit against the Secretary of the Alabama Department of Workforce, alleging that the Department’s handling of their unemployment benefits applications during the COVID-19 pandemic was unlawful. The plaintiffs claimed that the Department’s policies and practices resulted in unreasonable delays and inadequate communication, violating both the Social Security Act and the Due Process Clause of the Fourteenth Amendment. They sought various forms of injunctive relief, including orders requiring prompt decisions on applications, timely payment of approved claims, and clearer communication with claimants.The Montgomery Circuit Court granted the Secretary’s motion to dismiss the case, without specifying the grounds for dismissal. The plaintiffs’ motion to alter or vacate the judgment was denied. On appeal, the Supreme Court of Alabama affirmed the dismissal, holding that the plaintiffs had not exhausted their administrative remedies and that the courts lacked the power to address the merits of their claims. The plaintiffs then sought review by the United States Supreme Court.The United States Supreme Court reversed the Alabama Supreme Court’s judgment, holding that the state’s administrative exhaustion requirement could not be used to bar federal due process claims under 42 U.S.C. § 1983 for alleged delays in processing unemployment benefits. On remand, the Supreme Court of Alabama considered supplemental briefing on whether the case had become moot, as the Secretary asserted that all plaintiffs had either been paid or received final denials. The plaintiffs disputed this and requested a remand for a factual determination. The Supreme Court of Alabama remanded the case to the Montgomery Circuit Court to determine whether the case is now moot, instructing the lower court to resolve the factual dispute regarding mootness. View "Johnson v. Reed" on Justia Law

Lydia Galvez applied for Social Security disability insurance benefits, claiming disability from 2008 to 2018 due to various medical conditions. Her initial claim was denied by an Administrative Law Judge (ALJ) in 2013, who found she could perform light work. After Galvez appealed, the United States District Court for the Eastern District of Washington remanded the case in 2017 for further evaluation of her fibromyalgia diagnosis. On remand, the same ALJ, whose appointment had since been ratified, again denied benefits in 2019, incorporating parts of his earlier decision. Subsequent proceedings led to the assignment of a new ALJ, who held additional hearings, considered new evidence, and ultimately found Galvez not disabled for the period in question, though he found her disabled as of January 1, 2019 due to a new injury.After the new ALJ’s decision, Galvez again appealed to the district court, arguing that the decision was tainted by reliance on findings from the prior, improperly appointed ALJ, thus violating the Appointments Clause. The district court agreed, holding that the new ALJ’s decision was not independent because it incorporated portions of the earlier, tainted decision, and remanded the case for a new hearing before a different ALJ.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that a new ALJ’s decision is not automatically tainted by an Appointments Clause violation simply because it incorporates or echoes portions of a prior, tainted decision. The key inquiry is whether the new ALJ provided an independent assessment. The Ninth Circuit found that the new ALJ conducted additional hearings, considered new evidence, and made independent findings, thus satisfying the requirement for a fresh, independent review. The Ninth Circuit vacated the district court’s order and remanded for consideration of the merits of Galvez’s claim. View "GALVEZ V. BISIGNANO" on Justia Law

Catherine Baker was employed by San Mateo County as a Social Worker III but went on medical leave in 2009 due to back pain. In 2015, she returned to work in a different position as a screener trainee, which involved different duties but was compensated at the same pay rate as her original position. Her last paycheck was issued in January 2016. In 2017, Baker applied for a service-connected disability retirement, and the San Mateo County Employees Retirement Association (SamCERA) determined that the effective date for her retirement benefits should be January 22, 2016, the day after her last receipt of “regular compensation.”After SamCERA’s Board approved her application and set the effective date, Baker sought administrative review, arguing that her compensation as a screener trainee did not qualify as “regular compensation” under Government Code section 31724 because she had not returned to her original job. An administrative law judge recommended denial of her request to change the effective date, and the Board adopted this recommendation. Baker then filed a petition for writ of administrative mandamus in the Superior Court of San Mateo County, which denied the petition and confirmed the January 22, 2016 effective date.On appeal, the California Court of Appeal, First Appellate District, Division One, reviewed whether “regular compensation” under section 31724 included Baker’s pay as a screener trainee. Exercising independent judgment on statutory interpretation, the court held that “regular compensation” refers to regular salary or full wages, regardless of whether the position is the employee’s original job. Because Baker’s screener trainee pay matched her original position’s rate, it qualified as “regular compensation.” The court affirmed the trial court’s judgment, upholding the effective date set by SamCERA. View "Baker v. San Mateo County Employees Retirement Assn." on Justia Law