Justia Public Benefits Opinion Summaries

Plaintiff, an eleven-year-old special education student, lived in the Minnesota Independent School District No. 15 (district). An ALJ for the Minnesota Department of Education determined that the district had denied plaintiff a free appropriate public education (FAPE) within the meaning of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1482. After plaintiff filed an action in federal court seeking attorney fees and costs, both parties filed cross-motions for judgment on the administrative record. The district court reversed the ALJ's decision and denied plaintiff's motion for fees and costs and plaintiff appealed. The court affirmed the district court's judgment and held that plaintiff was not denied a FAPE where the district court did not fail to give "due weight" to the results of the administrative hearing; where the district court did not commit procedural violations of the IDEA; and where the district court did not violate the IDEA's substantive requirements.

Appellant appealed the district court's judgment upholding the Commissioner of Social Security's denial of his application for disability insurance and supplemental security income (SSI) benefits, under Title II and XVI of the Social Security Act (SSA), 42 U.S.C. 301 et seq. The court held that substantial evidence on the record supported the ALJ's finding that appellant's depression and anxiety were not severe; that the ALJ did not err in evaluating appellant's credibility; that, while the ALJ did not explicitly address the claims of appellant's girlfriend, the ALJ's error had no bearing on the outcome of appellant's case and did not require remand; and that the vocational expert's answer to a hypothetical question was not improper and constituted substantial evidence supporting the ALJ's determination. Accordingly, the court affirmed the judgment.

Plaintiff appealed the district court's grant of summary judgment dismissing claims of wrongful termination against her former employer, its president and chief executive officer, and its principal owner (collectively, defendants). At issue was whether plaintiff's claim of wrongful termination violated Iowa public policy. The court held that, in these circumstances, the district court correctly concluded that plaintiff's discharge did not undermine clearly defined public policy as a matter of law where plaintiff was discharged based on an at-will employment contract and where there was no false reimbursement claim submitted and no acts of fraud occurring on the part of defendants. Accordingly, the judgment of the district court was affirmed and the court denied as moot plaintiff's motion to strike portions of defendants' briefs.

Plaintiff appealed the district court's grant of summary judgment dismissing claims of wrongful termination against her former employer, its president and chief executive officer, and its principal owner (collectively, defendants). At issue was whether plaintiff's claim of wrongful termination violated Iowa public policy. The court held that, in these circumstances, the district court correctly concluded that plaintiff's discharge did not undermine clearly defined public policy as a matter of law where plaintiff was discharged based on an at-will employment contract and where there was no false reimbursement claim submitted and no acts of fraud occurring on the part of defendants. Accordingly, the judgment of the district court was affirmed and the court denied as moot plaintiff's motion to strike portions of defendants' briefs.

Appellants, on behalf of their disabled daughter, appealed the district court's finding that the Fort Osage R-1 School District ("school district") offered the daughter a free appropriate public education ("FAPE") within the meaning of the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. 1400, et seq., for the 2006-2007 school year. Appellants sought reimbursement for their costs of placing their daughter at a private facility during the school year. The court held that the district court did not err in concluding that the school district offered the daughter a FAPE and that the Individualized Education Plan put forward by the school district did not suffer from any procedural error. Accordingly, the court affirmed the judgment of the district court.

Plaintiff received disability insurance benefits under the Social Security Act 42 U.S.C. 301 et seq., between September 1994 and March 2004. After an investigation, the Social Security Administration ("SSA") notified plaintiff that she was ineligible for disability benefits because her employment income had exceeded SSA limits and determined that she was required to repay more than $60,000 in over paid benefits. At issue was whether the district court properly entered judgment for the SSA and denied plaintiff's waiver of over payment recovery and affirmed the ALJ's conclusion that it lacked authority to consider plaintiff's new argument contesting the amount of the overpayment itself. The court held that plaintiff failed to meet the administrative exhaustion requirement because she did not timely challenge her overpayment. Accordingly, since no final decision was made, the district court lacked jurisdiction under 42 U.S.C. 405(g) to consider plaintiff's challenge to the overpayment. The court also held that plaintiff was not entitled to a waiver of overpayment recovery because substantial evidence showed that she was not without fault in causing the overpayment and that the ALJ properly found that plaintiff knew or should have known that her work information was material because of her agreement to report such work in her benefit applications. Accordingly, the court affirmed the judgment of the district court.

Claimant appealed the district court's judgment upholding the Commissioner of Social Security's denial of her application for disability insurance. Appellant raised several issues of error on appeal. The court held that a certain physician's post-hearing letter did not contain any additional information and was not relied upon in the decision making process, and its receipt did not violate claimant's due process rights; that the ALJ did not err in finding claimant retained the residual functional capacity to perform certain kinds of low-stress work; that there was no error in the decision not to order a consultative examination regarding claimant's mental impairments; and that a hypothetical question posed to the Vocation Expert adequately addressed impairments supported by the record. Accordingly, the court affirmed the judgment where substantial evidence on the record as a whole supported the ALJ's decision.

Plaintiff sought disability insurance benefits under the Social Security Act, alleging that migraine headaches, affective mood disorder, and mayofascial back pain left her unable to work. At issue was whether the administrative law judge's ("ALJ") decision was supported by substantial evidence and whether the ALJ properly weighed physicians' opinions in determining plaintiff's residual functional capacity. The court concluded that substantial evidence supported the ALJ's decision to discredit plaintiff's subjective complaints where none of her doctors reported functional or work related limitations due to her headaches and where there was no basis for her creditability. The court also held that the ALJ properly weighed the physicians' opinions in determining plaintiff's residual functional capacity.

Appellants, a child with a learning disability and his parents, sued the Special School District No. 1 ("School District") in Minneapolis, Minnesota alleging that the School District violated his rights under the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. 1400, by denying him a free appropriate public education. At issue was whether the district court properly granted summary judgment in favor of the School District when it determined that the parents were not entitled to reimbursement from the School District for one year of private tuition when they transferred the child to a private education institution ("institution"). The court reversed the district court's decision and held that appellants were not precluded from reimbursement for tuition for the 2008-2009 academic year where the institution was a proper placement for the child and where the institution did not need to satisfy the least-restrictive environment requirement to be "proper" under the IDEA.

Appellant appealed the district court's order affirming the Social Security Administration's denial of his application for supplemental security income under 42 U.S.C. 405(g). At issue was whether the administrative law judge ("ALJ") failed to properly consider appellant's obesity, depression, and organic brain syndrome; improperly discredited appellant's subjective statements and certain medical evidence, and was biased against his doctor; and inadequately supported the ALJ's residual functional capacity assessment ("RFC"). The court held that the ALJ adequately considered appellant's obesity and that the ALJ's determination that appellant did not suffer from a debilitating mental impairment was supported by substantial evidence in the record as a whole. The court also held that the ALJ's decision to give less weight to a particular doctor's determination was reasonable where the doctor's determination contradicted other objective evidence in the record and that appellant provided no evidence to support his bias claims. The court further held that the ALJ adequately considered the evidence before deciding that appellant's subjective statements of pain were incredible. The court finally held that the ALJ considered all of appellant's physical and mental impairments which adequately supported the RFC assessment.