Justia Public Benefits Opinion Summaries

Strand served in the Navy for roughly 19-1/2 years until he was discharged under other than honorable conditions for firing a gun at his estranged wife. Strand was convicted in state court of three felonies. After his release from prison, Strand sought “corrections” to his service records, including a six-month credit so that he would have 20 years of service and be eligible for military retirement benefits. The Board for Correction of Naval Records recommended granting Strand’s request, citing his “overall record … of satisfactory service [including receiving numerous medals,].” The Secretary of the Navy rejected the Board’s recommendation, citing the seriousness of Strand’s convictions, the Navy’s core values, its practice in similar cases, and Strand’s supposed “long-standing history" of domestic violence issues. On remand, the Secretary also noted two early “counseling/warning” entries on Strand’s record and that Strand had already received “appropriate relief” in upgrading his service characterization to “General Under Honorable Conditions.” The Claims Court found the denial arbitrary.The Federal Circuit reinstated the denial. The Secretary reviewed the same record as the Board and drew a different, but supported, conclusion. Where a military officer has not unduly influenced the decision, a service secretary may reject the recommendation of a records correction board, even if supported by the record, if the rejection is not arbitrary or capricious, unsupported by substantial evidence, or otherwise contrary to the law. View "Strand v. United States" on Justia Law

Plaintiffs filed suit under the Individuals with Disabilities Education Act (IDEA), bringing a due process challenge to the school district's individualized education plan (IEP) and school placement before the Missouri Administrative Hearing Commission. The Commission affirmed the plan and placement, denying reimbursement. The district court reversed the Commission but limited the reimbursement award based on equitable considerations.The Eighth Circuit held that the school district violated the IDEA and the district court erred in limiting the award. As a preliminary matter, the court held that the school district's jurisdictional challenge was without merit; the school district's mootness challenge also failed; and the district court properly placed the burden on plaintiffs in the proceeding before it and correctly stated the standard of review on appeal.On the merits, the court held that the school district denied plaintiffs' son a free and appropriate education as required by the IDEA when it placed him at a school without direct occupational therapy or a sensory diet plan in place to address his autism-related issues. The court also held that an award limitation based on improvements to the school was inappropriate and inconsistent with the purposes of the IDEA because the school district failed to give any notice to plaintiffs. Furthermore, limiting an award based on improvements not communicated to plaintiffs was inconsistent with the IDEA's purpose. Accordingly, the court reversed the district court's limitation of tuition reimbursement and awarded full tuition reimbursement. View "D. L. v. St. Louis City School District" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court vacating a Department of Health and Human Services hearing officer's decision requiring AngleZ Behavioral Health Services to pay $392,603.31 in MaineCare reimbursements because of billing errors, holding that the superior court erred by finding that the Department did not submit proper evidence in support of some of its recoupment claims.After auditing the claims submitted by AngleZ between February 13, 2013 and July 20, 2013 The Department issued a notice of violation applying an error rate to all of AngleZ's claims during that time period. The Department ultimately sought a total recoupment of $392,603.31. A hearing officer concluded that the Department was correct in seeking 392,603.31 in recoupment, and the Department's acting commissioner adopted the recommendation. The superior court vacated the Commissioner's decision, concluding that the hearing officer's decision was not supported by substantial evidence. The Supreme Judicial Court vacated the superior court's judgment, holding that the hearing officer's decision was supported by substantial evidence and was neither arbitrary nor capricious. View "AngleZ Behavioral Health Services v. Department of Health and Human Services" on Justia Law

Plaintiff filed suit alleging that the school district violated the Individuals with Disabilities Education Act (IDEA) by failing to develop and implement an Individual Education Plan (IEP) that was reasonably calculated to provide him with educational benefits appropriate to his circumstances.Assuming arguendo that plaintiff was able to challenge all of the IEPs that the school district designed and implemented, the Fifth Circuit ultimately held that there was no IDEA violation. The court held that the district court properly considered the four factor test articulated in Cypress-Fairbanks lndep. Sch. Dist. v. Michael ex rel. Barry F., 118 F.3d 245, 247 (5th Cir. 1997), and concluded that all factors weighed in favor of the school district. In this case, the school district expended a great amount of time and resources developing and implementing an IEP that was based on multiple in-depth evaluations of plaintiff's unique needs and abilities with significant input from plaintiff's parents and expert consultants, and plaintiff achieved at least some academic and nonacademic benefits as a result of his plan. Accordingly, the court affirmed the district court's grant of summary judgment against plaintiff on his IDEA claim and dismissal of his remaining claims. View "R. S. v. Highland Park Independent School District" on Justia Law

The Fourth Circuit affirmed the denial of Social Security disability benefits to plaintiff, who claims that she has been unable to engage in any substantial gainful employment since November 2013, due to a combination of her back and shoulder impairments and a lifelong learning disorder.The court held that the ALJ's findings and the mental limitation included in the residual functional capacity (RFC) are sufficiently explained and supported by substantial evidence in the record. In this case, the ALJ addressed plaintiff's lifelong, borderline intellectual disability, including her moderate limitations in concentration, persistence, or pace; explained why the psychological evidence and plaintiff's statements support a mental limitation to simple, routine, and repetitive tasks; and included the mental limitation in the hypothetical question posed to the vocational expert. The court also held that the ALJ's finding that plaintiff can perform light work despite her physical limitations was supported by substantial evidence in the record. View "Shinaberry v. Saul" on Justia Law

The Fifth Circuit reversed the denial of social security disability benefits to plaintiff. The court held that the denial of benefits was not supported by substantial evidence, because the ALJ failed to apply the SSA's rules regarding borderline-age situations and did not provide any explanation for putting her in a lower age category. Accordingly, the court remanded for further proceedings. View "Schofield v. Saul" on Justia Law

The Ninth Circuit affirmed the district court's decision upholding the SSA's denial of the claimant's application for disability benefits under Titles II and XVI of the Social Security Act. The panel held that the ALJ properly provided specific and legitimate reasons for discounting the opinions of claimant's physicians, correctly concluded that claimant's impairments did not meet a listing, and was entitled to rely on the vocational expert's testimony despite the expert's failure to provide information about the sources underlying the testimony. View "Ford v. Saul" on Justia Law

Kentucky and Arkansas residents sued the Secretary of Health and Human Services based on the approval under 42 U.S.C. 1315(a) of an “experimental, pilot, or demonstration projects which, in the judgment of the Secretary, is likely to assist in promoting the objectives” of Medicaid. The district court held that the Secretary failed to analyze whether the projects would promote the primary objective of Medicaid—to furnish medical assistance. Kentucky terminated its project and obtained voluntary dismissal.The D.C. Circuit affirmed with respect to the Arkansas Works program, which required beneficiaries aged 19-49 to “work or engage in specified educational, job training, or job search activities for at least 80 hours per month,” except beneficiaries who show they are medically frail or pregnant, caring for a dependent child under age six, participating in a substance treatment program, or are full-time students. Works proposed to eliminate retroactive coverage, to lower the income eligibility threshold from 133% to 100% of the federal poverty line, and eliminated using Medicaid funds to assist beneficiaries in paying the premiums for employer-provided health care coverage. Instead of analyzing whether the demonstration would promote the objective of providing coverage, the Secretary identified three alternative objectives. Congress has not conditioned the receipt of Medicaid benefits on fulfilling work requirements or taking steps to end receipt of governmental benefits View "Gresham v. Azar" on Justia Law

Of two people injured in a car wreck in April 2012, one was a Medicare beneficiary who received her benefits from an MAO-Florida Healthcare Plus, which later assigned its claims to appellant MSPA Claims 1, LLC. The other party involved in the accident was insured by appellee Kingsway Amigo Insurance. The Medicare beneficiary obtained medical treatment for her accident-related injuries between April 29, 2012 and July 26, 2012, and Florida Healthcare made $21,965 in payments on her behalf. On March 28, 2013, the beneficiary settled a personal-injury claim with Kingsway and received a $6,667 settlement payment. The issue this case presented for the Eleventh Circuit’s review centered on the timeliness requirement with which the government had to comply as a prerequisite to filing suit to seek reimbursements that it made on behalf of the Medicare beneficiary, and whether filing suit beyond a statutory three-year period beginning on the date on which medical services were rendered was fatal to the government’s claim. The district court held that MSPA’s claim was stale because it didn’t comply with what the court (somewhat confusingly) called “the three-year limitation requirement.” The Eleventh Circuit disagreed and reversed. “The Medicare Secondary Payer Act’s private cause of action, and our cases interpreting it lead us to conclude that the Act’s claims-filing provision, doesn’t erect a separate bar that private plaintiffs must overcome in order to sue. A closer look at the claims-filing provision’s text and the Act’s structure confirms that conclusion. Accordingly, the district court erred in granting Kingsway’s motion for judgment on the pleadings.” View "MSPA Claims 1, LLC v. Kingsway Amigo Insurance Company" on Justia Law

Central Mississippi Medical Center (CMMC) appealed a Chancery Court decision denying its appeal of a Division of Medicaid (DOM) hearing. The DOM had determined that CMMC owed it $1.226 million due to overpayment. The Mississippi Supreme Court recently decided a reimbursement dispute involving the DOM, Crossgates River Oaks Hosp. v. Miss. Div. of Medicaid, 240 So. 3d 385 (Miss. 2018). In Crossgates, the hospitals prevailed because the DOM had failed to adhere to the Medicare State Plan Agreement. Applying the same legal principles to this case, the Supreme Court ruled the DOM prevailed because the DOM adhered to the Plan. The chancellor found sufficient evidence to support the DOM’s decision, decreed that it was neither arbitrary nor capricious, and decreed that it did not exceed the DOM’s authority or violate any of CMMC’s statutory or constitutional rights. View "Central Mississippi Medical Center v. Mississippi Division of Medicaid" on Justia Law