Justia Public Benefits Opinion Summaries

Plaintiff alleged a disability due to gout, arthritis, back pain, diabetes, high blood pressure, and obesity. In this appeal, he challenged the denial of his application for disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. 405. The ALJ found that plaintiff was capable of performing his past relevant work as a farm worker. The court concluded that the ALJ's determination that plaintiff's residual functioning capacity (RFC) to do medium work, with some limitations, is supported by substantial evidence and that the ALJ sufficiently developed the record. In this case, the objective medical findings do not support the degree of limitation alleged by plaintiff. Finally, the court rejected plaintiff's contention that the ALJ failed to adequately develop the record. Accordingly, the court affirmed the judgment. View "Buford v. Colvin" on Justia Law

Plaintiff, who suffers from Ehlers-Danlos Syndrome, filed suit against the Department after it denied him "shelter needy" benefits, raising claims under 42 U.S.C. 1983; the Americans with Disabilities Act (ADA), 12 U.S.C. 12101 et seq.; and the Rehabilitation Act (RA), 29 U.S.C. 701 et seq. The court concluded that the appeal was timely, rejecting the district court's conclusion that plaintiff did not timely file notice and proof of service; concluded that the Rooker-Feldman doctrine is inapplicable to judicial review of executive action, including determinations made by a state administrative agency; and disagreed with the district court’s conclusion that section 256.045 of the Minnesota statutes prevented the court from exercising supplemental jurisdiction over the appeal from a state agency’s decision. In interpreting Minn. Stat. 256.045, subd. 7, the court concluded that subdivision 7 lays out one permissible route through which an aggrieved party may appeal from the Commissioner’s order and thus prevent it from becoming final, but it does not strip the federal court of its authority to hear the same appeal through the exercise of supplemental jurisdiction. Because the district court improperly concluded that it lacked jurisdiction based solely on the state statute, the district court failed to determine whether it should exercise supplemental jurisdiction under 28 U.S.C. 1367 or whether any abstention doctrine applied. Therefore, the court vacated the decision dismissing the supplemental state-law claim and remanded for further consideration. Because the state agency’s decision was not final, the district court erred by finding that plaintiff’s ADA and RA claims were precluded. Finally, the court agreed with the district court that plaintiff's allegations failed to state a due process or equal protection claim. Because plaintiff’s equal protection claim is predicated on the same allegations as his ADA and RA claims, the district court did not err by dismissing the section 1983 claim. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Wong v. Minnesota DHS" on Justia Law

Robert Dean Carter appealed the denial of his application for disability insurance benefits and supplemental security income. The ALJ concluded that Carter was not disabled because he did not have an impairment or combination of impairments that met or medically equaled one of the listed impairments for chronic heart failure and because Carter had the residual functional capacity (RFC) to perform a limited range of sedentary work. After Carter died, Carter's daughter, KKC, appealed the denial of benefits. The court concluded that substantial evidence supports the ALJ’s finding that Carter’s impairment did not meet section 4.02(B)(1) and 4.02(B)(3); the ALJ did not err by refusing to give controlling weight to the opinion of Carter's treating physician where the physician's statement at issue did not resolve the legal issue of whether Carter was disabled; and the ALJ’s RFC assessment was supported by substantial evidence on the record as a whole. Accordingly, the court affirmed the judgment. View "KKC v. Colvin" on Justia Law

SEARK, operator of two hospice-care facilities, voluntarily entered into a provider agreement with the Secretary of Health and Human Services to receive Medicare reimbursement pursuant to the Medicare Act, 42 U.S.C. 1395c, 1395f(a)(7), 1395cc. The Act annually caps Medicare reimbursement. SEARK filed suit after the Secretary sent it seven demands for repayment, arguing that the cap violates the Takings Clause of the Fifth Amendment. The district court concluded that SEARK’s voluntary participation in the Medicare program precludes a takings claim. The court concluded that SEARK has not met its burden to prove the demands for repayment based on the statutory cap are a taking where the reimbursement cap allocates the government's capacity to subsidize healthcare; SEARK presented no evidence to suggest the cap makes it impossible to profitably engage in their business; and SEARK voluntarily chose to participate in the Medicare hospice program. Accordingly, the court affirmed the judgment. View "Southeast Arkansas Hospice v. Burwell" on Justia Law

Plaintiff, complaining of right-shoulder and arm pain, appealed the denial of his application for disability benefits. The court concluded that the ALJ's denial of benefits is supported by substantial evidence because plaintiff has the residual functioning capacity (RFC) to perform sedentary work, and the ALJ limited plaintiff to work involving no overhead reaching with his right arm. Further, the medical evidence supports the RFC. Accordingly, the court affirmed the judgment. View "Liner v. Colvin" on Justia Law

Plaintiff, suffering a combination of impairments such as paranoid schizophrenia and depression, appealed the denial of his applications for disability insurance benefits (DIB) and supplemental security income (SSI). Plaintiff asserts that the ALJ’s residual functioning capacity (RFC) assessment does not adequately account for all the limitations he suffers due to the combination of paranoid schizophrenia, panic attacks, and chronic depression. The court found that the the ALJ did not rely solely on the opinions of the state agency doctors and sufficiently considered the medical records provided by plaintiff in assessing his RFC. The ALJ did consider the opinion of plaintiff's expert, but concluded that it was inconsistent with the rest of the doctor's report. Further, the ALJ also considered plaintiff's Global Assessment of Functioning (GAF) scores, but found that they were not controlling. In this case, the ALJ concluded that plaintiff's symptoms were reasonably controlled by medication and treatment. Therefore, substantial evidence supports the ALJ's RFC determination and the RFC determination included the necessary limitations to account for plaintiff's mental impairments. Accordingly, the court affirmed the judgment. View "Mabry v. Colvin" on Justia Law

Plaintiff appealed the denial of disability benefits under Title II of the Social Security Act, 42 U.S.C. 401 et seq., and supplemental security income benefits under Title XVI of the Act, 42 U.S.C. 1381 et seq. The court concluded that the errors identified by plaintiff show the ALJ failed to consider Mental Impairment Listing 12.07 Somatoform Disorders (including Conversion Disorder) when assessing her residual functional capacity; the ALJ failed to evaluate fully the vocational expert's testimony; the testimony of plaintiff's sister-in-law reflects on the severity of plaintiff's impairments and the ALJ's failure to address this testimony was not harmless nor an arguable deficiency in opinion-writing technique; and the ALJ erred by disregarding the opinion of plaintiff's treating physician and improperly accorded great weight to statements in the physician's treatment notes indicating that plaintiff demonstrated improvement without acknowledging that plaintiff's symptoms waxed and waned throughout the substantial period of treatment. Accordingly, the court remanded with instructions. View "Nowling v. Colvin" on Justia Law

Plaintiff appealed the denial of her application for Social Security disability insurance benefits and supplemental security income. The court concluded that substantial evidence supported the ALJ’s finding that plaintiff did not meet the requirements for mental retardation in Listing 12.05C; that the ALJ characterized plaintiff's impairment as mild mental retardation at step two did not preclude the ALJ on this record from finding at step three that plaintiff did not exhibit deficits in adaptive functioning; and therefore, the court affirmed the judgment. View "Ash v. Colvin" on Justia Law

Plaintiff appealed the denial of social security disability benefits and supplemental security income. The ALJ provided valid reasons for discounting plaintiff's subjective complaints and the court held that the ALJ's less-than-fully credible determination is supported by substantial evidence; the ALJ's residual functioning capacity (RFC) is supported by substantial evidence; and the ALJ gave proper weight to plaintiff's treating physicians where the opinions were not supported by the record as a whole. Accordingly, the court affirmed the denial of benefits. View "Chaney v. Colvin" on Justia Law

Plaintiffs seek to represent a class of dual status National Guard technicians who had their benefits determined prior to the court's issuance of Petersen v. Astrue and would like to have their benefits readjusted to take advantage of the decision to avoid application of the Windfall Elimination Provision (WEP). The district court dismissed the complaint for lack of jurisdiction. The court affirmed the district court's decision to reject the application of mandamus jurisdiction where the district court held that there is no clear, nondiscretionary duty on behalf of the SSA to apply the Peterson decision to plaintiffs. The court also concluded that plaintiffs failed to present a colorable constitutional claim on equal protection grounds that would justify the application of the exception to 42 U.S.C. 405(g)’s jurisdictional limitations. Plaintiffs’ due process claim also does not support application of an exception to 405(g). Accordingly, the court affirmed the judgment. View "Mitchael v. Colvin" on Justia Law