Justia Public Benefits Opinion Summaries

Jonathan Cain applied for supplemental security income (SSI) due to severe impairments, including degenerative disc disease, migraine headaches, obesity, depression, and anxiety. Despite his conditions, an administrative law judge (ALJ) determined that Cain could perform certain types of work and denied his disability benefits. Cain challenged this decision in federal court.The United States District Court for the Southern District of Indiana affirmed the ALJ's decision, holding that substantial evidence supported the ALJ's conclusion. The court found that the ALJ met the minimal articulation requirements in assessing the medical evidence and did not err in relying on the vocational expert's testimony.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the ALJ's decision was supported by substantial evidence. The ALJ adequately evaluated the medical opinions of Cain's treating physician, Dr. Amanda Williams, and the state agency psychologists, Dr. Joelle Larsen and Dr. Ken Lovko. The ALJ also properly relied on the vocational expert, Thomas Dunleavy, who provided a reliable basis for his job number predictions. The court concluded that the ALJ did not commit legal error and affirmed the district court's judgment. View "Cain v Bisignano" on Justia Law

Fletcher Properties, Inc. and other appellants own multi-tenant residential properties in Minneapolis. The City of Minneapolis enacted an ordinance prohibiting property owners from refusing to rent to individuals based on requirements of public assistance programs, including Section 8 housing vouchers. Fletcher challenged the ordinance, claiming it violated the Minnesota Constitution’s Takings Clause and was preempted by the Minnesota Human Rights Act (MHRA).The district court initially ruled in favor of Fletcher, finding the ordinance violated due process and equal protection clauses. The court of appeals reversed this decision, and the Minnesota Supreme Court affirmed, remanding the case to address the remaining claims. On remand, the district court granted summary judgment for the City, rejecting Fletcher’s takings and preemption claims. The court of appeals affirmed this decision, leading to the current appeal.The Minnesota Supreme Court reviewed the case and held that the ordinance does not constitute a physical or regulatory taking under the Minnesota Constitution. The court applied the Penn Central factors, concluding that the economic impact of the ordinance, interference with investment-backed expectations, and the character of the government action did not support a finding of a regulatory taking. The court also determined that the ordinance does not effect a physical taking as landlords voluntarily rent their properties and are not compelled to continue doing so.Additionally, the court held that the ordinance is not preempted by the MHRA. The court found no conflict between the ordinance and the MHRA, as the MHRA does not grant landlords an affirmative right to reject voucher holders. The court also concluded that the MHRA does not occupy the field of housing discrimination based on public assistance, allowing for local regulation.The Minnesota Supreme Court affirmed the decision of the court of appeals, upholding the ordinance. View "Fletcher Properties, Inc. vs. City of Minneapolis" on Justia Law

Jada Padua applied for Social Security benefits, claiming disability due to fibromyalgia, chronic fatigue, depression, and anxiety. An administrative law judge (ALJ) denied her benefits, concluding that she was not disabled as defined by the Social Security Act and that jobs existed in significant numbers in the national economy that she could perform. Padua challenged the agency’s denial in federal court, but the district court upheld the ALJ's decision, finding substantial evidence to support it.Padua filed her disability benefits application in November 2010, initially claiming a disability onset date of July 2008, later amended to November 2010. After an initial denial and a remand by a magistrate judge in February 2016, the ALJ held a second hearing in August 2016. The ALJ determined that Padua was not disabled under the Social Security Act, finding that her impairments did not meet a listing for presumptive disability and that she had the residual functional capacity (RFC) to perform light work with additional limitations. The ALJ discounted Padua’s complaints of extreme pain and fatigue, noting inconsistencies with her daily activities and the overall medical record. The ALJ also gave little weight to the opinions of her treating physicians, Drs. Carpenter and Pendolino, finding them inconsistent with the evidence.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The court held that the ALJ’s assessment of Padua’s fibromyalgia and the opinions of Drs. Carpenter and Pendolino were supported by substantial evidence. The court found that the ALJ reasonably considered the objective medical evidence, treatment history, and daily activities in determining Padua’s RFC. The court also concluded that the ALJ provided adequate reasons for discounting the treating physicians’ opinions and that the RFC determination was supported by substantial evidence. View "Padua v. Bisignano" on Justia Law

Christian Arnold retained Binder & Binder in April 2018 to represent him in a claim for disability benefits under the Social Security Act. After the Commissioner of Social Security denied his claim, Arnold appealed to the district court, which remanded the case to the agency. An administrative law judge later determined Arnold was entitled to $160,797.10 in past-due benefits. Binder then moved for attorneys' fees under 42 U.S.C. § 406(b), seeking twenty-five percent of the retroactive benefits, amounting to $40,199.27. The district court awarded Binder $16,920, reducing the fee based on an effective hourly rate of $600.The United States District Court for the Central District of Illinois initially awarded Binder $16,920, despite the contingency fee agreement. Binder appealed, and the United States Court of Appeals for the Seventh Circuit held that the district court abused its discretion by not anchoring its reasonableness analysis on the contingency fee agreement. The case was remanded for further proceedings. On remand, the district court again awarded $16,920, maintaining that the contingency fee should be reduced to reflect a more reasonable effective hourly rate. Binder appealed once more.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the district court abused its discretion by inadequately explaining its decision to reduce Binder’s fees. The appellate court emphasized that the district court must begin with the contingency fee agreement and consider relevant factors, such as the plaintiff’s satisfaction and the attorney’s expertise. The appellate court reversed the district court’s decision and remanded with instructions to order the Social Security Administration to remit attorneys’ fees at Binder’s requested amount of $34,199.27. View "Arnold v. Bisignano" on Justia Law

Donald Thorpe sought disability benefits, claiming that his health issues rendered him unable to work. The Administrative Law Judge (ALJ) denied his claim, relying on the testimony of a vocational expert. Thorpe appealed to the district court, which affirmed the ALJ’s decision, stating that Thorpe forfeited any challenge to the expert testimony by failing to object timely and that the decision was supported by substantial evidence.The district court found that Thorpe did not object to the vocational expert’s testimony during the hearing or in a post-hearing brief, thus forfeiting his right to challenge it. The court also determined that the ALJ’s decision was based on substantial evidence, including the expert’s testimony, which was consistent with the Dictionary of Occupational Titles (DOT) and supported by the expert’s qualifications and experience.The United States Court of Appeals for the Seventh Circuit reviewed the case and agreed with the district court. The court held that Thorpe forfeited his ability to challenge the expert’s testimony by not objecting during the hearing. The court also found that the ALJ’s decision was supported by substantial evidence, as the expert’s testimony had sufficient indicia of reliability, including consistency with the DOT and the expert’s qualifications.The Seventh Circuit affirmed the district court’s decision, concluding that the ALJ did not err in relying on the vocational expert’s testimony to determine that Thorpe was not disabled and could find other gainful employment. View "Thorpe v Bisignano" on Justia Law

A skilled nursing facility accepted a new resident who was receiving Medicaid benefits. The resident's husband was designated as her authorized representative. Nearly two years later, the Department of Human Services (DHS) terminated the resident's Medicaid benefits due to excess assets. Both the resident and her husband were incapacitated, and the resident's public guardian submitted a new Medicaid application, which was denied. The nursing facility continued to care for the resident without compensation until her death. The facility later sought an administrative hearing to challenge the eligibility decision, but the request was denied because the facility was not an authorized representative and the appeal was late.The circuit court and the Intermediate Court of Appeals (ICA) affirmed the denial, holding that the nursing home lacked standing to challenge the eligibility determination under Hawai'i Revised Statutes (HRS) § 346-12, which limits appeals to the applicant or recipient. The courts concluded that the nursing home did not have a close relationship with the resident for third-party standing purposes.The Supreme Court of the State of Hawai'i reviewed the case and disagreed with the lower courts regarding standing. The court held that skilled nursing facilities have constitutionally protected property interests in compensation for medical services performed for residents based on DHS eligibility determinations. The court ruled that these facilities have due process rights under the Hawai'i Constitution, including notice and the opportunity to appeal Medicaid eligibility determinations when the beneficiary is incapacitated and no authorized representative is available or willing to appeal. The court vacated the ICA's judgment and the circuit court's order, remanding the case for a new administrative hearing on the merits of the resident's Medicaid eligibility. View "In re FT" on Justia Law

Dionne Marie Nadon applied for disability insurance benefits and supplemental security income in April 2015 and May 2016, respectively, citing conditions such as fibromyalgia, spinal abnormalities, depression, and anxiety. The administrative law judge (ALJ) initially denied her applications in January 2017, finding she could return to her past work as a cashier/checker. On appeal, the case was remanded because the ALJ had not adequately addressed Nadon’s post-traumatic stress disorder (PTSD). On remand, the ALJ again determined that Nadon was not disabled, following the five-step sequential analysis for determining disabilities.The ALJ found that Nadon had engaged in substantial gainful activity as a personal care attendant from July 2021 through 2022 but continued the analysis due to a continuous period of at least twelve months during which Nadon did not engage in substantial gainful activity. The ALJ found that Nadon had severe impairments but did not have an impairment or combination of impairments that met or equaled the severity of a listed impairment. The ALJ determined that Nadon’s residual functional capacity allowed her to perform light work with certain limitations and found that she could perform her past relevant work as a personal care attendant and other work as a housekeeper, marker, or small products assembler.The district court affirmed the ALJ’s decision. The United States Court of Appeals for the Ninth Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that the ALJ did not err by considering Nadon’s work as a personal care attendant, as an ALJ is permitted to consider any work done by a claimant when evaluating a disability claim. The court also found that the ALJ provided several reasons for discounting Nadon’s testimony and the opinions of several healthcare professionals, beyond her work as a personal care attendant. The court rejected Nadon’s argument that the ALJ erred by relying on the vocational expert’s testimony, as it relied on the rejected premise that the ALJ erred in discounting the healthcare professionals’ opinions. View "Nadon v. Bisignano" on Justia Law

Dawn Drumgold, a former employee of the Social Security Administration, applied for Social Security disability benefits in 2020, citing mental health issues including depression, bipolar disorder, and PTSD. Her application included medical records from her primary-care doctor, Dr. Sylvia Luther, and her mental-health counselor, Shideh Sarmadi, as well as reports from an independent examiner and two consultants. The records and reports provided conflicting assessments of her level of impairment.The Administrative Law Judge (ALJ) reviewed the evidence and found that Drumgold's limitations were moderate, not severe enough to qualify for disability benefits. The ALJ found Dr. Luther's records, which often noted that Drumgold's depression was in remission, more persuasive than Sarmadi's unsupported and conclusory submissions. The ALJ also found the reports from the two consultants, who concluded that Drumgold had only moderate limitations, to be consistent with the overall record.Drumgold appealed the ALJ's decision to the Social Security Appeals Council, which declined to reverse it. She then took her case to the United States District Court for the Eastern District of Virginia, which upheld the ALJ's decision, finding that it was supported by substantial evidence.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The court held that the ALJ had reasonably assessed the persuasiveness of the medical opinions based on their supportability and consistency with the overall record. The court found that substantial evidence supported the ALJ's conclusion that Drumgold's limitations were moderate and that she retained some capacity for work. View "Drumgold v. Commissioner of Social Security" on Justia Law

Rachael Gorecki applied for disability benefits and received a hearing before an administrative law judge (ALJ) whose appointment was ratified by Nancy Berryhill during her second tenure as Acting Commissioner of the Social Security Administration. The ALJ denied Gorecki's benefits application, and the Social Security Administration's Appeals Council denied review, making the decision final. Gorecki then sued, arguing that the ALJ had no constitutional authority to issue a decision because Berryhill's second stint as Acting Commissioner violated the Federal Vacancies Reform Act (FVRA).The United States District Court for the Northern District of Alabama rejected Gorecki's argument, aligning with other appellate courts that had ruled on similar issues. The district court found that Berryhill's second tenure as Acting Commissioner was lawful under the FVRA.The United States Court of Appeals for the Eleventh Circuit reviewed the case and joined five other circuits in holding that the FVRA authorized Berryhill's second stint as Acting Commissioner. The court found that the plain text of the FVRA allowed Berryhill to serve again as Acting Commissioner once a nomination for the office was submitted to the Senate, regardless of whether the nomination occurred during the initial 210-day period. The court affirmed the district court's judgment, concluding that Berryhill's ratification of the ALJ's appointment was valid and that the ALJ had the authority to deny Gorecki's benefits application. The Eleventh Circuit thus affirmed the lower court's decision. View "Gorecki v. Commissioner, Social Security Administration" on Justia Law

Ferida H. Moy suffers from severe PTSD due to her experiences during the Yugoslav Wars. She applied for disability insurance benefits and supplemental security income, citing her PTSD and related mental health issues. An administrative law judge (ALJ) denied her application, finding that she had the residual functional capacity to perform simple, routine tasks with minimal contact with supervisors and co-workers. This decision was upheld by the district court, leading Moy to appeal.The ALJ found that Moy had moderate limitations in concentrating, persisting, or maintaining pace but concluded that she could work at a consistent production pace. The ALJ's decision was based on the testimony of a vocational expert who stated that a person with Moy's limitations could work as a dining room attendant, bus person, scrap sorter, industrial cleaner, or dishwasher. However, the vocational expert also testified that regular absences or being off-task for more than 15% of the workday would result in job loss. The ALJ's decision was affirmed by the district court.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the ALJ failed to build a logical bridge between Moy's limitations and the conclusion that she could work at a consistent production pace. The court noted that the ALJ's determination did not adequately account for Moy's limitations in concentration, persistence, and pace. The court emphasized that the ALJ's reasoning was internally inconsistent and did not reflect Moy's documented symptoms and treatment needs. Consequently, the Seventh Circuit vacated the judgment and remanded the case to the Commissioner of Social Security for further consideration consistent with its opinion. View "Moy v Bisignano" on Justia Law