Justia Public Benefits Opinion Summaries

The Eighth Circuit reversed and remanded the district court's denial of disability insurance benefits and supplemental security income to plaintiff. The court held that the ALJ failed to provide a good reason for disregarding the treating physician's opinion when, after noting that the patient's subjective complaints formed the basis for the doctor's opinion, the ALJ stated only that she declined to accept portions of the treating physician's functional capacities assessment. View "Walker v. Commissioner, Social Security Administration" on Justia Law

The district court affirmed the denial of social security disability benefits to claimant, holding that substantial evidence supported the ALJ's finding that claimant had the residual functional capacity to perform sedentary work. In this case, the ALJ did not err by discounting the treating physician's opinions because they conflicted with claimant's treatment records. View "Adkins v. Commissioner, Social Security Administration" on Justia Law

After the Settlement Agreement Appeal Panel affirmed the Claim Administrator's classification of the Arcadia Facility as a "Failed Business," Graphic Packaging sought and was denied discretionary review from the district court. The Fifth Circuit affirmed the district court's denial of discretionary review, holding that the Appeals Panel did not misapply the Settlement Agreement. Even if it did, Graphic Packaging merely disputed the correctness of a discretionary administrative decision in the facts of a single claimant's case. The court rejected Graphic Packaging's remaining claim that the decision merits review because it contradicts a previous Appeals Panel decision. View "Claimant ID 100262194 v. BP Exploration & Production, Inc." on Justia Law

The Supreme Court reversed the opinion of the district court affirming the decision of the Nebraska Department of Health and Human Services (DHHS) terminating the Medicaid benefits of Eric S., holding that the corpus of a trust was not available to Eric for purposes of determining his Medicaid eligibility.Specifically, the Court held (1) the trust at issue was properly characterized as a testamentary trust; (2) applying Pohlmann v. Nebraska Department of Health & Human Services, 710 N.W.2d 639 (Neb. 2006), the trust was a discretionary trust, and Eric did not have the ability to compel distribution of the entire corpus; and (3) therefore, it was error to find the entire trust corpus was an available resource in evaluating Eric’s eligibility for Medicaid. View "Donna G. v. Nebraska Department of Health & Human Services" on Justia Law

Hansen served in the Army National Guard for six years, which included, at the start of his service in 1959, 182 days of active duty for training. Hansen died from amyotrophic lateral sclerosis (ALS) in 1998. In 2009, his widow applied to the VA for benefits under 38 U.S.C. 1310(a), which provides that “[w]hen any veteran dies after December 31, 1956, from a service-connected or compensable disability, the Secretary shall pay dependency and indemnity compensation to such veteran’s surviving spouse, children, and parents.” A 2008 regulation declares that “the development of [ALS] manifested at any time after discharge or release from active military, naval, or air service is sufficient to establish service connection for that disease.” 38 C.F.R. 3.318(a) (ALS Rule). The Board of Veterans’ Appeals and the Veterans Court held that Hansen’s “active duty for training” service does not qualify as active duty, and denied the benefits claim. The Federal Circuit affirmed. The 38 U.S.C.101(24) definition of “active military, naval, or air service” has been interpreted as excluding training in these circumstances. View "Hansen-Sorensen v. Wilkie" on Justia Law

Lindh, a law enforcement officer, took blows to the head during training. He subsequently had severe headaches lasting between several hours and two days. A month later, Lindh suddenly lost most of the vision in his left eye. Two treating physicians did not believe the vision loss was related to the blows. Dr. Kaye, a neuro-ophthalmologist, the Qualified Medical Examiner (QME), agreed with the other physicians, that Lindh’s “blood circulation to his left eye was defective,” absent the injury,” Lindh likely would have retained a lot of his vision. He agreed that even had Lindh not suffered the blows, he could have lost his vision due to this underlying condition; it was “unlikely” Lindh would have suffered a vision loss if he had not had the underlying “vascular spasticity,” a rare condition. His professional opinion was that: 85% of the permanent disability was due to his old condition and 15% was due to the work injury. The ALJ rejected that analysis and found Lindh had 40 percent permanent disability without apportionment between his underlying condition and the work-related injury. The Board affirmed, concluding that the preexisting conditions were mere risk factors for an injury entirely caused by industrial factors; the QME had “confused causation of injury with causation of disability.” The court of appeal ordered an apportioned award. Dr. Kaye’s opinion was consistent with the other physicians' opinions, that it was unlikely the trauma caused the loss of vision. Whether an asymptomatic preexisting condition that contributed to the disability would, alone, have inevitably resulted in disability, is immaterial. View "City of Petaluma v. Workers' Compensation Appeals Board" on Justia Law

Neighbors is a skilled nursing facility participating in Medicare and Medicaid. The Centers for Medicare and Medicaid Services (CMS) determined that Neighbors inadequately addressed sexual interactions between three cognitively impaired residents and that Neighbors’ failure to act put the residents in “immediate jeopardy,” and issued Neighbors a citation and an $83,800 penalty under 42 U.S.C. 1395i‐3(h)(2)(B)(ii)(I). An ALJ and the Department of Health and Human Services Departmental Appeals Board upheld the decision. The Seventh Circuit affirmed, concluding that substantial evidence supports the Agency’s determinations and rejecting claims that the sexual interactions were consensual. The court noted findings that staff, aware of the sexual interactions, did not talk to the residents about their feelings about these “relationships”; did not document the residents’ capacity for consent (or lack thereof) or communicate with residents’ physicians for medical assessment of how their cognitive deficits impacted that capacity; did not discuss the developments with the residents’ responsible parties; and did not record any monitoring of the behaviors or make any care plans to account for them. Neighbors’ non‐intervention policy prevented any real inquiry into consent, except in the extreme situation where a resident was yelling or physically acting out. View "Neighbors Rehabilitation Center, LLC v. United States Department of Health and Human Services" on Justia Law

Petitioner Kyle Guillemette challenged a determination by the Administrative Appeals Unit (AAU) of the New Hampshire Department of Health and Human Services (DHHS) that the notice requirements set forth in RSA 171-A:8, III (2014) and New Hampshire Administrative Rules, He-M 310.07 did not apply when Monadnock Worksource notified Monadnock Developmental Services of its intent to discontinue providing services to petitioner because that act did not constitute a “termination” of services within the meaning of the applicable rules. Petitioner received developmental disability services funded by the developmental disability Medicaid waiver program. MDS was the “area agency,” which coordinated and developed petitioner’s individual service plan. Worksource provides services to disabled individuals pursuant to a “Master Agreement” with MDS. Worksource began providing day services to the petitioner in August 2012. On March 31, 2017, Worksource notified MDS, in writing, that Worksource was terminating services to petitioner “as of midnight on April 30.” The letter to MDS stated that “[t]he Board of Directors and administration of . . . Worksource feel this action is in the best interest of [the petitioner] and of [Worksource].” Petitioner’s mother, who served as his guardian, was informed by MDS of Worksource’s decision on April 3. The mother asked for reconsideration, but the Board declined, writing that because the mother “repeatedly and recently expressed such deep dissatisfaction with our services to your son, the Board and I feel that you and [petitioner] would be better served by another agency . . . .” Thereafter, petitioner filed a complaint with the Office of Client and Legal Services alleging that his services had been terminated improperly and requesting that they remain in place pending the outcome of the investigation of his complaint. Because the New Hampshire Supreme Court concluded that the AAU’s ruling was not erroneous, it affirmed. View "Petition of Kyle Guillemette" on Justia Law

At issue in this appeal was whether the district court lacked subject matter jurisdiction to consider Azar Webb’s 42 U.S.C. 1983 claim in the same lawsuit in which the court considered an appeal from a contested case under the Administrative Procedure Act (APA) and whether, as a result, the court lacked the authority to award Webb attorney fees.After the Nebraska Department of Health and Human Services (DHHS) ended Webb’s Medicaid benefits and denied his petition for reinstatement, Webb filed a claim in the district court under the APA for unlawful termination of Medicaid eligibility, adding a claim of violation of his federal rights under section 1983. The district court reversed DHHS’ decision and ordered reinstatement of Webb’s coverage and reimbursement of medical expenses that should have been covered. The court further found in favor of Webb as to his 1983 claim and enjoined DHHS officials from denying Webb Medicaid eligibility. The Supreme Court affirmed, holding that once the district court resolved Webb’s APA claim, the court had the authority to grant Webb relief under section 1983 and his request for attorney fees pursuant to 42 U.S.C. 1988. View "Webb v. Nebraska Department of Health & Human Services" on Justia Law

Nursing Homes, on behalf of eleven residents, filed suit against the Secretaries, alleging that the Secretaries wrongfully denied the residents Medicaid benefits in violation of the Fourteenth Amendment and several federal statutes.The Fourth Circuit affirmed the district court's dismissal of the complaint for lack of subject matter jurisdiction and failure to state a claim. The court held that the Eleventh Amendment barred the Nursing Homes' constitutional and Medicaid Act claims for damages or other relief based on past actions; the Nursing Homes' claims for declaratory and injunctive relief were moot and required dismissal because the court lacked subject matter jurisdiction; and, because the Nursing Homes failed to state a viable Americans with Disabilities Act claim, they failed to state a cognizable Rehabilitation Act claim. View "Wicomico Nursing Home v. Padilla" on Justia Law