Justia Public Benefits Opinion Summaries

Ramona Craig applied for Social Security disability benefits and, after her application was denied, she filed suit challenging that denial. The key issue in her case was whether she had properly exhausted her administrative remedies before seeking judicial review. The magistrate judge specifically warned Craig that she needed to present sufficient evidence of exhaustion prior to proceeding with her lawsuit. Despite these warnings, Craig did not provide the necessary evidence before the district court entered final judgment.The United States District Court for the Western District of Texas reviewed Craig’s case and dismissed it without prejudice, finding that she had failed to demonstrate exhaustion of administrative remedies. After the district court entered its final judgment, Craig submitted an additional document intended to establish exhaustion, but this filing occurred after the judgment was entered.On appeal, the United States Court of Appeals for the Fifth Circuit considered whether it could review Craig’s post-judgment filing. The Fifth Circuit held that, under Rule 10(a) of the Federal Rules of Appellate Procedure, the record on appeal does not include documents filed in the district court after the entry of final judgment. The court further declined to exercise its discretion to take judicial notice of the post-judgment filing. The Fifth Circuit affirmed the district court’s dismissal without prejudice, holding that the district court lacked subject matter jurisdiction because Craig failed to establish exhaustion of administrative remedies based on the filings made before final judgment. The court clarified that Craig may file a new case or seek to reopen the existing case if she wishes to pursue her claims. View "Craig v. Bisignano" on Justia Law

The plaintiff, a former machine operator with a high school education, stopped working after a workplace injury and subsequently experienced a range of medical issues, including spinal stenosis, degenerative joint disease, carpal tunnel syndrome, arthritis, depression, and anxiety. In November 2018, she applied for disability insurance benefits, claiming her disability began in March of that year. Her application was denied at multiple stages within the Social Security Administration (SSA), including after a hearing before an administrative law judge (ALJ). The SSA Appeals Council denied her request for review, prompting her to seek judicial review.The United States District Court for the Northern District of Mississippi reversed and remanded the ALJ’s decision, instructing the ALJ to specifically evaluate certain medical opinions, including that of Dr. William Booker, in accordance with relevant regulations. On remand, the ALJ held another hearing, considered extensive medical evidence and testimony, and again found that while the plaintiff had several severe impairments and could not perform her past work, she retained the residual functional capacity to perform light work with certain restrictions. The ALJ concluded that jobs existed in significant numbers in the national economy that she could perform, and thus she was not disabled. The Appeals Council adopted this as the final decision of the Commissioner. The district court, with the consent of both parties, affirmed the Commissioner’s decision, and the plaintiff appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit reviewed whether the Commissioner’s decision was supported by substantial evidence and whether proper legal standards were applied. The court held that the ALJ’s decision was supported by substantial evidence and that any alleged errors did not prejudice the plaintiff’s substantial rights. The court affirmed the judgment of the district court. View "Madkins v. Bisignano" on Justia Law

William Dexter Lucas was involved in schemes to fraudulently obtain small-business loans from the government and vehicle loans from private institutions. He pleaded guilty to conspiracy to commit bank and wire fraud and waived his right to appeal. His presentence investigation report (PSR) included details of his fraudulent activities and mentioned allegedly fraudulent social security benefits he had been receiving. At sentencing, the district court ordered Lucas to pay restitution to both the private institutions and the Social Security Administration (SSA). Lucas appealed his sentence, challenging the restitution orders for the vehicle loans and social security benefits.The United States District Court for the Southern District of Texas initially handled the case. Lucas objected to the PSR's restitution calculations, arguing that the vehicle loans restitution was ordered to the wrong victim and incorrectly calculated, and that the social security benefits restitution was improper because he was entitled to the benefits and the alleged fraud was not part of the same scheme as the offenses in his indictment. The district court recalculated the vehicle loans restitution but upheld the SSA restitution, finding that Lucas's statement to the SSA was fraudulent and that the SSA fraud was part of the same conduct as the fraud alleged in the indictment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the SSA restitution was erroneous because the SSA fraud was not part of the same scheme or conspiracy as the offenses in the indictment. The court affirmed the vehicle loans restitution, finding that Lucas's challenge to the calculation was barred by his appeal waiver and that the dealerships were proper victims. The court affirmed the vehicle loans restitution but vacated the SSA restitution award. View "United States v. Lucas" on Justia Law

Plaintiff suffers from physical, cognitive, and psychological impairments. In this appeal, plaintiff challenged the denial of her social security disability benefits. The court concluded that the ALJ legally erred by rejecting an examining physician's opinion without explanation. In this case, the physician opined that plaintiff could not work any job that entailed standing for longer than 30 minutes or walking farther than 50 years. Accordingly, the court vacated and remanded for the ALJ to consider plaintiff's impairments, taking into account the examining physician's opinion. View "Kneeland v. Berryhill" on Justia Law

In the underlying action, JCHCC sought to permanently enjoin the Parish from evicting it from two Parish-owned facilities in which JCHCC currently provides medical services to medically underserved populations. The district court granted JCHCC's motion for a preliminary injunction, enjoining the Parish from evicting JCHCC but allowing it to terminate the injunction by establishing that the medical needs of the population currently served by the relevant JCHCC facilities would be met if JCHCC were evicted. The court reversed, concluding that JCHCC has not established a substantial likelihood of success on the merits of the only claim that was properly before the court. In this case, JCHCC failed to establish a likelihood of success on the merits of its Medicaid violation claim where JCHCC does not point to any authority suggesting that every local government in every participating state must provide the relevant medical services, nor does it point to authority establishing that the Parish has any obligation under Louisiana state law to provide such services on behalf of the state. View "Jefferson Community Health Care Centers v. Jefferson Parish Government" on Justia Law

Plaintiff challenged the denial of disability insurance benefits, arguing that the ALJ erred by failing to ask a testifying vocational expert whether her testimony was consistent with the Dictionary of Occupational Titles (DOT), as required by an agency policy interpretation ruling, but nonetheless relying on that testimony. The court concluded that the ALJ's procedural error was harmless and does not warrant reversal. Because plaintiff does not raise any other grounds for reversal, the court affirmed the judgment. View "Graves v. Colvin" on Justia Law

In response to secretly recorded videos released by the Center for Medical Progress depicting conversations with Planned Parenthood employees elsewhere, LDHH terminated PPGC Louisiana Medicaid provider agreements. PPGC and the Individual Plaintiffs filed suit against LDHH under 42 U.S.C. 1983, alleging violations of 42 U.S.C. 1396a(a)(23) and the First and Fourteenth Amendments of the U.S. Constitution. The Individual Plaintiffs, three women who are Medicaid beneficiaries and who receive medical care from one of PPGC’s Louisiana facilities, seek to continue receiving care from PPGC’s facilities. The Individual Plaintiffs contend that LDHH’s termination action will deprive them of access to the qualified and willing provider of their choice, PPGC, in violation of Medicaid’s free-choice-of-provider provision. The district court entered a preliminary injunction against LDHH’s termination of PPGC’s Medicaid provider agreements. The court held that the Individual Plaintiffs met their burden to show their entitlement to a preliminary injunction; the district court did not abuse its discretion in preliminarily enjoining LDHH’s termination of PPGC’s provider agreements; and thus the court affirmed the district court's preliminary injunction, remanding for further proceedings. View "Planned Parenthood v. Gee" on Justia Law

Plaintiffs filed suit against the City, arguing that the City's pension reforms violate the Texas Constitution, Tex. Const. art. XVI 66(d). Two district courts ruled in favor of the City. In these consolidated appeals, the court concluded that Section 66 permits prospective changes to the pension plans of the public employees within its reach. In this case, the Pension Reform complies with Section 66 where Section 66 did not turn plaintiffs’ variable-rate cost-of-living adjustment into a one-way ratchet capable only of upward movement. The court rejected claims raised by plaintiffs of Case No. 15-10416, that only the Texas legislature has the City of Dallas v. Trammel "reserved power" to amend pension plans and thus abrogate contractual rights. The court concluded that this argument is foreclosed by Klumb v. Houston Mun. Employees Pension Sys. Finally, the court concluded that the Pension Reform does not violate the United States Constitution’s contracts clause and takings clause where neither clause create property rights and the right to public pension benefits in Texas is subject to legislative power. Accordingly, the court affirmed the district court's judgments. View "Houten, Jr. v. City of Fort Worth" on Justia Law

Plaintiff, complaining chiefly of neck pain, appealed the denial of his application for disability benefits. The court concluded that the newly submitted evidence - namely, updated treatment records - was not so significant as to require remand to the ALJ for additional consideration; substantial evidence supports the ALJ's determination at step three of the evaluation process that plaintiff did not meet or medically equal Listing 1.04(A); and the ALJ's residual functioning capacity (RFC) finding is supported by substantial evidence where the ALJ found that plaintiff was capable of performing light work with certain limitations. The court agreed with the ALJ's ultimate determination that plaintiff was not disabled and affirmed the judgment. View "Whitehead v. Colvin" on Justia Law

Plaintiffs, a class of children eligible for Texas's Early and Periodic Screening, Diagnosis, and Treatment program, filed suit under 42 U.S.C. 1983 for violations of federal Medicaid law. Plaintiffs subsequently entered into a consent decree with various Texas state officials (defendants) calculated to improve implementation of the Program. In 2007, the parties agreed to a "Corrective Action Order." In 2013, defendants moved to terminate a portion of the Order and associated consent decree paragraphs under Rule 60(b)(5). The district court granted the motion and plaintiffs appealed. Determining that plaintiffs have not forfeited their appeal, the court concluded that the district court properly terminated the portion of bullet points 8-10 concerning the completion of the four assessments at issue. The court relied on certain district court decisions to interpret the proper interpretation of "shortage" - which compares the provider-to-class-member ratio with the average client load of the relevant class of provider - and concluded that the district court erred in terminating the portion of bullet points 8-10 that orders defendants to develop plans to address “shortage[s]” identified by the assessments. Accordingly, the court vacated the district court's order in part and remanded for further proceedings. The court affirmed the portion of the district court’s order terminating bullet points 6-7 and consent decree paragraph 93, and the court vacated the portion of the district court's order terminating the challenged sentence of bullet point 5. View "Frew v. Janek" on Justia Law