Justia Public Benefits Opinion Summaries

The case involves Melissa Palmer, who applied for Pandemic Unemployment Assistance (PUA) benefits due to loss of income from her self-employment as a sign-language interpreter during the COVID-19 pandemic. Despite continuing to work her second job at Woofs and Waves, she did not report this income in her weekly requests for benefits. The South Dakota Department of Labor and Regulation, Reemployment Assistance Division (Department) determined that she had misrepresented her income and was therefore ineligible for the benefits she had received. The Department ordered her to repay the benefits and assessed a mandatory penalty.The administrative law judge (ALJ) upheld the Department's decision, finding that Palmer had willfully misrepresented her income. The circuit court affirmed the ALJ’s decision. Palmer appealed, arguing that she had not willfully misrepresented her income because she believed she only needed to report her self-employment income.The Supreme Court of the State of South Dakota reversed the lower courts' decisions. The Court found that the ALJ's finding that Palmer believed she only needed to report her self-employment income was inconsistent with the conclusion that she had willfully misrepresented her income. The Court held that a willful misrepresentation requires evidence of intentional misrepresentation, not merely knowledge of the falsity of the representation. The Court remanded the case for the ALJ to reconsider whether Palmer was at fault for the overpayment and whether she was eligible for a waiver. View "Palmer V. Dep’t Of Labor & Regulation" on Justia Law

Lonnie Reidburn, a self-employed insurance agent, appealed a decision by the South Dakota Department of Labor, Reemployment Assistance Division (Department) that he must repay $24,690 in pandemic unemployment benefits he received. Reidburn's income was based on commissions he received for new policies and renewals, which required in-person visits to clients' homes or businesses. During the COVID-19 pandemic, Reidburn experienced a significant reduction in his ability to procure new policies and renewals because clients did not want him to make in-person visits. As a result, Reidburn's income decreased. He applied for Pandemic Unemployment Assistance (PUA) through the Department and received benefits for 39 weeks. However, the Department later determined that Reidburn's loss of income was not the direct result of the pandemic and issued a determination of ineligibility.The administrative law judge (ALJ) upheld the Department's determination of ineligibility, reasoning that the individual decisions of Reidburn's clients to preclude him from entering their homes or places of business were not a direct result of the pandemic. However, the ALJ rejected the Department's at-fault determination and found that Reidburn was not at fault for the overpayment. The ALJ also concluded that Reidburn's request for a waiver was untimely. Reidburn appealed the ALJ's decision to the circuit court, which affirmed the ALJ's decision.The Supreme Court of the State of South Dakota reversed the ALJ's determination that Reidburn was ineligible to receive PUA benefits for 35 of the 39 weeks at issue, based on its recent decision in Bracken v. South Dakota Department of Labor and Regulation, Reemployment Assistance Division. The court declined to address the Department's argument that Reidburn failed to present sufficient evidence to support his testimony that he experienced a significant reduction in services, as the Department did not raise this argument at Reidburn's administrative hearing. The court affirmed the circuit court's denial of Reidburn's motion for attorney fees. View "Reidburn v. Department of Labor & Regulation" on Justia Law

The Supreme Court affirmed the judgment of the circuit court entering judgment in favor of Yankton County on Sacred Heart Health Service Inc.'s (Hospital) declaratory judgment against the County, holding that circuit court did not err in holding S.D. Codified Laws chapter 28-13 is the proper mechanism for the Hospital to obtain reimbursement from the County for medical costs associated with the twenty-three patients in the involuntary commitment process.The Hospital brought a declaratory judgment action against the County seeking a declaration as to the County's liability and reimbursement for charges for the medical care and treatment of patients subject to an emergency hold under S.D. Codified Laws chapter 27A-10. The circuit court first entered a memorandum decision in favor of the Hospital, but after granting the County's motion to reconsider issued a second memorandum decision and corresponding judgment in favor of the County. The Supreme Court affirmed, holding (1) the circuit court did not err in granting the County's motion for summary judgment; (2) the Hospital did not have a claim in quantum merit for reimbursement from the County; and (3) the circuit court did not err in granting the County's motion to reconsider. View "Sacred Heart Health Services v. Yankton County" on Justia Law