Justia Public Benefits Opinion Summaries

Brandon Phillips, who had several Missouri marijuana-possession convictions, pleaded guilty to a federal felon-in-possession charge. Despite Missouri legalizing marijuana and planning to expunge certain convictions, the district court sentenced him to 120 months in prison and imposed a lifetime ban on federal benefits.The United States District Court for the Eastern District of Missouri overruled Phillips's objection that his criminal history was overstated due to Missouri's legalization of marijuana. The court stated it would have imposed the same sentence regardless of the marijuana convictions. Phillips's marijuana convictions were still on record at the time of sentencing, although they were later expunged. Phillips argued that the expungement should require resentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that Phillips did not preserve the expungement issue for appellate review, as he did not clearly state the grounds for his objection in the district court. The court also determined that even if the issue had been preserved, the district court would have imposed the same sentence based on the 18 U.S.C. § 3553(a) factors, considering Phillips's reoffending on parole and possession of a large quantity of fentanyl.However, the Eighth Circuit vacated the federal-benefits ban, finding it was a plain error to apply it to Phillips, as the ban only applies to drug distributors, not gun possessors. The court held that the district court's application of the ban was clearly incorrect and affected Phillips's substantial rights. The court affirmed the 120-month prison sentence but vacated the federal-benefits ban. View "United States v. Phillips" on Justia Law

Chesla A. Scott challenged the Idaho Department of Labor's service of three determination notices, claiming she did not receive them while temporarily working out-of-state. The Department mailed the notices to her last known address, and Scott missed the fourteen-day appeal period. When she attempted to appeal, the Department's Appeals Examiner dismissed her appeal as untimely. Scott argued that the Department's service by mail did not meet constitutional due process requirements.The Appeals Examiner conducted a hearing and concluded that Scott's appeal was untimely under Idaho Code section 72-1368(3) and (5). The Idaho Industrial Commission affirmed this decision, denying Scott's request for a new hearing and conducting a de novo review of the record. The Commission also concluded that Scott had not timely filed her appeal.Scott appealed to the Idaho Supreme Court, arguing that the Department's service by mail was constitutionally inadequate. The Court reviewed whether Scott exhausted her administrative remedies and preserved her constitutional challenge. The Court held that Scott had exhausted her administrative remedies and preserved her due process claim, allowing it to be reviewed.The Idaho Supreme Court affirmed the Commission's decision, holding that the Department's mailing of the determination notices was reasonable under all the circumstances and did not violate due process. The Court found that the Department's method of service was reasonably calculated to provide notice, and Scott's failure to receive the notices was not due to any fault of the Department. The Court did not award attorney fees to either party but awarded costs to the Department. View "Scott v. Home Depot USA, Inc." on Justia Law

S.S. was receiving temporary housing assistance through the Department for Children and Families (DCF) and staying at a shelter. After a confrontation with shelter staff over a mistakenly reassigned locker, S.S. was asked to vacate the shelter without prior warning. Consequently, DCF imposed a thirty-day period of ineligibility for further temporary housing assistance due to the shelter-rule violation. S.S. requested a fair hearing to challenge this decision, and a hearing officer recommended reversing the ineligibility period, which DCF subsequently did.S.S. then filed a motion with the Human Services Board to adopt the hearing officer’s findings and issue a final order. The hearing officer questioned the mootness of the case since DCF had already lifted the ineligibility period. The Board ultimately dismissed the case as moot, concluding there was no further relief it could provide since DCF had already granted S.S. the requested relief.The Vermont Supreme Court reviewed the case and affirmed the Board’s decision. The Court held that the Board lacked the statutory authority to provide the relief S.S. sought, as the Board can only affirm, modify, or reverse DCF decisions and provide appropriate relief. Since DCF had already reversed the ineligibility period, there was no live controversy for the Board to address. The Court also found that the capable-of-repetition-yet-evading-review exception to the mootness doctrine did not apply, as S.S. did not demonstrate a reasonable expectation of being subjected to the same action again. Consequently, the Board’s dismissal of the case was appropriate. View "In re appeal of S.S." on Justia Law

Jerry L. Blankenship applied for living miner benefits under the Black Lung Benefits Act, claiming he suffered from coal dust-induced pneumoconiosis and was totally disabled. An Administrative Law Judge (ALJ) found Blankenship entitled to a rebuttable presumption of total disability due to pneumoconiosis under 30 U.S.C. § 921(c)(4) and determined that his former employer, Island Creek Coal Company, failed to rebut this presumption. Consequently, Blankenship was awarded benefits. The Benefits Review Board affirmed the ALJ’s decision.Island Creek petitioned for review, arguing that the ALJ improperly conflated the presence of pneumoconiosis and disability causation with the separate total disability analysis. Additionally, Island Creek contended that the ALJ failed to adequately explain his decision to credit the opinions of Blankenship’s medical experts over those of Island Creek’s experts.The United States Court of Appeals for the Fourth Circuit reviewed the case and agreed with Island Creek. The court found that the ALJ improperly relied on the presence of pneumoconiosis and the causation of Blankenship’s impairment in concluding that he was totally disabled. The court also determined that the ALJ failed to provide a sufficient explanation for crediting the medical opinions of Drs. Nader and Green over those of Drs. McSharry and Sargent, violating the duty of explanation under the Administrative Procedure Act.The Fourth Circuit granted Island Creek’s petition for review, vacated the decision of the Benefits Review Board, and remanded the case with instructions for the Board to return Blankenship’s case to the ALJ for reconsideration consistent with the court’s opinion. View "Island Creek Coal Co. v. Blankenship" on Justia Law

Amra Schmitz, a 52-year-old former public relations representative, applied for Social Security disability benefits in February 2020, claiming disability since January 2018. After a telephonic hearing, the Administrative Law Judge (ALJ) applied the five-step disability analysis and concluded that despite Schmitz's limitations and inability to perform her past job, there were still jobs she could perform. The ALJ found that Schmitz had severe impairments but did not meet the criteria for disability. The ALJ determined that Schmitz could perform light work with certain restrictions and identified six types of unskilled jobs she could do.The Appeals Council denied review of the ALJ's decision, and Schmitz filed suit in the United States District Court for the Central District of Illinois. Schmitz argued that the ALJ's decision was not supported by substantial evidence, particularly criticizing the vocational expert's (VE) testimony regarding the number of available jobs. The district court found that Schmitz had forfeited this objection by not raising it during the hearing or in post-hearing briefs and upheld the ALJ's decision.The United States Court of Appeals for the Seventh Circuit reviewed the district court's decision de novo, applying the same deferential standard. The court noted that Schmitz did not object to the VE's testimony during the hearing, thus forfeiting her objection. The court found that the VE's testimony was coherent, plausible, and based on her expertise. The court also determined that the ALJ had no duty to further investigate the VE's job-number estimates in the absence of an objection. The court concluded that the ALJ's decision was supported by substantial evidence and affirmed the district court's judgment. View "Schmitz v. Colvin" on Justia Law

Shannon Montgomery filed a claim for disability benefits in May 2013, citing medical conditions including chiari malformation, syringomyelia, syrinx cavities, and degenerative disc disorder. An administrative law judge (ALJ) denied his claim, and the Appeals Council declined to review the decision. Montgomery then sought judicial review. In 2016, the district court reversed the SSA's decision and remanded the case, ordering a consultative examination and consideration of Montgomery's work history. Despite this, the ALJ again denied the claim without the required examination, leading to another remand. Eventually, after multiple remands and hearings, the ALJ denied the claim again in January 2022, finding Montgomery had severe impairments but could perform light work.The district court affirmed the ALJ's decision, and Montgomery appealed to the United States Court of Appeals for the Eighth Circuit. The appellate court reviewed the case de novo, focusing on whether the ALJ's decision was supported by substantial evidence. The court noted that the ALJ followed the five-step process for determining disability and found that Montgomery's impairments did not meet or equal any listed impairments. The ALJ concluded that Montgomery had the residual functional capacity (RFC) to perform light work and could adjust to other work available in the national economy.The Eighth Circuit addressed Montgomery's arguments regarding the 2016 Remand Order and found that the ALJ had complied with the order by considering Montgomery's work history and obtaining a consultative examination. The court also found that substantial evidence supported the ALJ's RFC assessment and denial of benefits, including opinions from state agency physicians and a medical expert. Consequently, the Eighth Circuit affirmed the district court's judgment, upholding the denial of Montgomery's disability benefits. View "Montgomery v. O'Malley" on Justia Law

Nattalia Castell was employed as a senior accountant for Money Metals Exchange, LLC. She was discharged after allegedly mishandling an Idaho Department of Labor (IDOL) notice regarding her boyfriend's unemployment benefits application. Castell applied for unemployment benefits, but an IDOL appeals examiner excluded her boyfriend from testifying, denied her request to reopen the hearing to read a statement, and found that she was terminated for employment-related misconduct, making her ineligible for benefits.Castell appealed to the Idaho Industrial Commission, which denied her request to reopen the hearing and affirmed the appeals examiner's decision. The Commission found that Castell's actions constituted misconduct, as she failed to disclose a conflict of interest and mishandled the notice. Castell then appealed to the Idaho Supreme Court.The Idaho Supreme Court reviewed the case and affirmed the Commission's decision. The Court held that the appeals examiner did not err in excluding the boyfriend's testimony or in denying Castell's request to reopen the hearing. The Court also found that the Commission's determination that Castell was discharged for employment-related misconduct was supported by substantial and competent evidence. The Court concluded that Castell's actions disregarded a standard of behavior that Money Metals had a right to expect from its employees, and her claim of retaliation was not supported by evidence. View "Castell v. IDOL" on Justia Law

Consuelo Griselda Nerio Mejia challenged the denial of her disability benefits by the Social Security Administration (SSA). After an administrative law judge (ALJ) denied her application, concluding that despite her severe impairments, she could perform other jobs available in the national economy, Nerio Mejia filed a civil suit. She raised three objections to the ALJ's decision, but the district court only addressed her claim that the ALJ improperly rejected her symptomology testimony, finding that the ALJ failed to provide clear and convincing reasons for doing so. The court reversed the ALJ's decision and remanded the case to the SSA for further proceedings.The United States District Court for the Central District of California found that the SSA's position was not substantially justified, making Nerio Mejia eligible for attorneys' fees under the Equal Access to Justice Act (EAJA). However, the district court reduced the fee award, excluding time spent on two additional issues that the court did not address, citing the Ninth Circuit's decision in Hardisty v. Astrue. The court concluded that fees for work on issues not decided by the court were not compensable under the EAJA.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court's order reducing the fee award. The Ninth Circuit held that the district court misapplied Hardisty, which did not address the compensability of fees for undecided issues. The appellate court found that the district court's ruling was contrary to the Supreme Court's decision in Hensley v. Eckerhart and the Ninth Circuit's en banc decision in Ibrahim v. United States Department of Homeland Security. These cases establish that a fully compensatory fee should be awarded when a plaintiff achieves excellent results, even if some issues were not decided. The Ninth Circuit remanded the case with instructions to award the full amount of fees requested by Nerio Mejia. View "MEJIA V. O'MALLEY" on Justia Law

Johnathan Bertsch was charged with two counts of deliberate homicide and two counts of attempted deliberate homicide after shooting at a vehicle, killing one person and injuring two others, and subsequently shooting a highway patrol officer. He pleaded guilty to one count of deliberate homicide and three counts of attempted deliberate homicide. The State requested $34,728.14 in restitution based on payments made to the victims by Montana’s Crime Victim Compensation Program. Bertsch, who relied on Social Security payments and had not maintained employment, objected to the restitution due to his indigent status.The Fourth Judicial District Court sentenced Bertsch to four consecutive life terms without parole and imposed the requested restitution amount plus a 10% administrative fee. The court reasoned that any funds Bertsch earned through prison work should go towards restitution. Bertsch appealed the restitution order, arguing that it should be waived as unjust given his financial inability to pay.The Supreme Court of the State of Montana reviewed the case. The court held that the restitution statutes require courts to determine restitution amounts without considering an offender’s ability to pay. Bertsch did not adequately request a waiver or present sufficient evidence to show that restitution was unjust under § 46-18-246, MCA. The court found that a general objection based on indigence did not meet the burden of proof required to waive restitution. The court affirmed the District Court’s order, noting that Bertsch could petition for a waiver or adjustment of restitution if his circumstances changed. View "State v. Bertsch" on Justia Law

K.M., an adult with multiple disabilities, including autism and a seizure disorder, has been receiving Medicaid-funded developmental disabilities services for over twenty years. These services, provided by Washington County Mental Health Services (WCMHS), were supposed to include more than thirty hours of community support each week. However, since March 2020, K.M. has only received two to five hours of support weekly, leading to negative health effects.K.M. petitioned the Human Services Board to order the Department of Disabilities, Aging, and Independent Living (DAIL) to provide the full services he is entitled to. The Board dismissed his petition, stating it failed to specify the action required for compliance and that an order to provide services without available staff was too vague. The Board also interpreted K.M.'s request as seeking a broader policy change, which it deemed outside its authority, citing Husrefovich v. Department of Aging & Independent Living.The Vermont Supreme Court reviewed the case and reversed the Board's dismissal. The Court held that the Board has the statutory authority to order DAIL to provide the services K.M. is entitled to under federal and state law. The Court clarified that while the Board cannot issue broad policy injunctions, it can provide specific relief to individuals. The Court found K.M.'s request for services clear and specific enough to inform DAIL of the required action. The case was remanded to the Board for further proceedings consistent with this opinion. View "In re Appeal of K.M." on Justia Law