Justia Public Benefits Opinion Summaries

Lydia Galvez applied for Social Security disability insurance benefits, claiming disability from 2008 to 2018 due to various medical conditions. Her initial claim was denied by an Administrative Law Judge (ALJ) in 2013, who found she could perform light work. After Galvez appealed, the United States District Court for the Eastern District of Washington remanded the case in 2017 for further evaluation of her fibromyalgia diagnosis. On remand, the same ALJ, whose appointment had since been ratified, again denied benefits in 2019, incorporating parts of his earlier decision. Subsequent proceedings led to the assignment of a new ALJ, who held additional hearings, considered new evidence, and ultimately found Galvez not disabled for the period in question, though he found her disabled as of January 1, 2019 due to a new injury.After the new ALJ’s decision, Galvez again appealed to the district court, arguing that the decision was tainted by reliance on findings from the prior, improperly appointed ALJ, thus violating the Appointments Clause. The district court agreed, holding that the new ALJ’s decision was not independent because it incorporated portions of the earlier, tainted decision, and remanded the case for a new hearing before a different ALJ.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that a new ALJ’s decision is not automatically tainted by an Appointments Clause violation simply because it incorporates or echoes portions of a prior, tainted decision. The key inquiry is whether the new ALJ provided an independent assessment. The Ninth Circuit found that the new ALJ conducted additional hearings, considered new evidence, and made independent findings, thus satisfying the requirement for a fresh, independent review. The Ninth Circuit vacated the district court’s order and remanded for consideration of the merits of Galvez’s claim. View "GALVEZ V. BISIGNANO" on Justia Law

A plaintiff who lost his job during the COVID-19 pandemic applied for and received regular unemployment benefits from the Washington State Employment Security Department (ESD). After exhausting those benefits, he applied for and received additional benefits under the federally funded Pandemic Emergency Unemployment Compensation (PEUC) program, created by the CARES Act. Following an audit, ESD redetermined his eligibility, reduced his weekly benefit, and assessed overpayments, sending him multiple, confusing notices with inconsistent information and deadlines. While the plaintiff appealed, ESD began offsetting his ongoing PEUC benefits to recover the alleged overpayments.An administrative law judge later found that ESD’s notices failed to provide adequate explanation or legal basis for the benefit reductions and overpayment assessments, and ordered ESD to issue a new redetermination. ESD reimbursed the plaintiff for the offset amounts, but its system continued to show a balance owed. The plaintiff, on behalf of himself and similarly situated individuals, filed a putative class action in the United States District Court for the Western District of Washington, alleging deprivation of property without due process under the Fourteenth Amendment and the Social Security Act. The district court held that while the plaintiff had a property interest in regular unemployment benefits, he did not have a constitutionally protected property interest in PEUC benefits, because state participation in the PEUC program was voluntary and could be terminated at any time.On interlocutory appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s ruling. The Ninth Circuit held that the CARES Act’s PEUC program, once a state opted in, created a constitutionally protected property interest in PEUC benefits for eligible individuals. The Act’s mandatory language and objective eligibility criteria significantly constrained state discretion, giving rise to legitimate claims of entitlement. The case was remanded for further proceedings. View "STERLING V. FEEK" on Justia Law

Dionne Marie Nadon applied for disability insurance benefits and supplemental security income in April 2015 and May 2016, respectively, citing conditions such as fibromyalgia, spinal abnormalities, depression, and anxiety. The administrative law judge (ALJ) initially denied her applications in January 2017, finding she could return to her past work as a cashier/checker. On appeal, the case was remanded because the ALJ had not adequately addressed Nadon’s post-traumatic stress disorder (PTSD). On remand, the ALJ again determined that Nadon was not disabled, following the five-step sequential analysis for determining disabilities.The ALJ found that Nadon had engaged in substantial gainful activity as a personal care attendant from July 2021 through 2022 but continued the analysis due to a continuous period of at least twelve months during which Nadon did not engage in substantial gainful activity. The ALJ found that Nadon had severe impairments but did not have an impairment or combination of impairments that met or equaled the severity of a listed impairment. The ALJ determined that Nadon’s residual functional capacity allowed her to perform light work with certain limitations and found that she could perform her past relevant work as a personal care attendant and other work as a housekeeper, marker, or small products assembler.The district court affirmed the ALJ’s decision. The United States Court of Appeals for the Ninth Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that the ALJ did not err by considering Nadon’s work as a personal care attendant, as an ALJ is permitted to consider any work done by a claimant when evaluating a disability claim. The court also found that the ALJ provided several reasons for discounting Nadon’s testimony and the opinions of several healthcare professionals, beyond her work as a personal care attendant. The court rejected Nadon’s argument that the ALJ erred by relying on the vocational expert’s testimony, as it relied on the rejected premise that the ALJ erred in discounting the healthcare professionals’ opinions. View "Nadon v. Bisignano" on Justia Law

Christopher Obrien applied for disability insurance benefits and supplemental security income, claiming various medical conditions rendered him disabled since August 2010. He reported past work as a telemarketer in 2003 and 2009 and as a door-to-door salesperson in 2013 and 2014. The Social Security Administration (SSA) denied his claim, and an Administrative Law Judge (ALJ) upheld this decision, concluding Obrien could perform his past relevant work as a telemarketer and sales representative.Obrien challenged the ALJ's decision in the United States District Court for the Central District of California, arguing his telemarketing work was too old or insubstantial to count as past relevant work. The Commissioner conceded that substantial evidence did not support the ALJ's finding regarding Obrien's ability to perform his past work as a sales representative. However, the district court upheld the denial of benefits, finding Obrien's objections to the ALJ's determination regarding his telemarketing work both forfeited and meritless.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court rejected the Commissioner's argument that Obrien had forfeited his objections by not raising them before the ALJ, noting that SSA ALJ hearings are informal and nonadversarial, and ALJs are required to fully investigate the issues. The court held that substantial evidence did not support the ALJ's determination that Obrien's telemarketing work in 2003 and 2009 counted as past relevant work. The 2003 work was outside the 15-year period required by the regulations, and there were ambiguities regarding the average monthly wages for the 2009 work, necessitating further record development by the ALJ.The Ninth Circuit reversed the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "OBRIEN V. BISIGNANO" on Justia Law

Ronald Myers pleaded guilty in 2005 to possessing an implement for counterfeiting state securities and transporting a stolen motor vehicle across state lines. He was sentenced to 60 months in prison, 3 years of supervised release, and ordered to pay $40,406 in restitution. Myers completed his sentence in 2010 but was reincarcerated in 2013 on other charges. Since then, over $30,500 has been deposited into his inmate trust account, mostly from family and friends, with a smaller portion from prison wages. Myers still owes over $35,000 in restitution.The United States District Court for the Eastern District of Washington granted the government's motion to turn over funds from Myers's inmate trust account to apply to his restitution obligation. The court rejected Myers's request for an evidentiary hearing to determine which funds were prison wages, concluding that the government had provided sufficient evidence of the account's composition. The court held that the Mandatory Victims Restitution Act (MVRA), 18 U.S.C. § 3664(n), applies to substantial aggregated sums from multiple sources, not just one-time financial windfalls.The United States Court of Appeals for the Ninth Circuit affirmed the district court's order. The court held that § 3664(n) applies to substantial resources from any source, including gradual accumulations from family and friends, and not just to one-time windfalls. The court also found that the district court did not abuse its discretion in declining to hold an evidentiary hearing, as the existing documentary evidence was sufficient. The court concluded that the turnover order did not contravene the judgment's restitution provisions and was consistent with the MVRA's goal of ensuring prompt restitution to victims. View "United States v. Myers" on Justia Law

The plaintiff, Mya Noelia Fallon, applied for Supplemental Security Income (SSI) under the Social Security Act, citing epileptic seizures and cognitive and behavioral limitations. Her application included assessments from her neurologist, Dr. Joseph Drazkowski, and licensed professional counselor (LPC) Terry Galler, who noted significant cognitive impairments and anxiety disorders. An Administrative Law Judge (ALJ) found Fallon not disabled, giving minimal weight to the opinions of Dr. Drazkowski and LPC Galler, and discrediting other medical and lay testimony.The United States District Court for the District of Arizona partially reversed the ALJ's decision, finding errors in the discounting of some witnesses but agreeing with the ALJ's assessment of Dr. Drazkowski's and LPC Galler's opinions. The case was remanded for further consideration. On remand, the ALJ again found Fallon not disabled, incorporating the prior evaluations. Fallon appealed, and the district court affirmed the ALJ's decision, refusing to revisit its prior conclusions about the medical opinions based on the law-of-the-case doctrine.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the law-of-the-case doctrine applies in the social security context, meaning that the district court did not abuse its discretion by refusing to reconsider the evaluations of Dr. Drazkowski and LPC Galler. The court explained that a social-security applicant has two options to preserve the right to appeal: immediately appeal the remand order or proceed on remand, understanding that the district court may decline to revisit settled issues. The Ninth Circuit affirmed the district court's decision, noting that Fallon forfeited her ability to challenge the evaluations by not raising the issue in her first appeal. View "FALLON V. DUDEK" on Justia Law

John Hudnall, a former financial advisor, applied for disability benefits under the Social Security Act, claiming he had been unable to work since May 1, 2015, due to major depressive disorder, anxiety, and insomnia. His application included a function report from his wife, Miyuki Sato, detailing his limitations in daily activities and self-care. Despite this, the Social Security Administration denied his application and request for reconsideration. Hudnall then sought a hearing before an Administrative Law Judge (ALJ), who also denied his claim, finding him not disabled based on medical evidence and Hudnall's self-reported activities, without explicitly addressing Sato's lay evidence.Hudnall appealed to the United States District Court for the Northern District of California, which granted summary judgment in favor of the Social Security Administration. Hudnall then appealed to the United States Court of Appeals for the Ninth Circuit.The Ninth Circuit reviewed the case and affirmed the district court's judgment. The court held that under the Social Security Administration's new regulations, effective March 27, 2017, ALJs are no longer required to provide germane reasons for discounting lay witness testimony. The court found that these regulations, which state that ALJs are not required to articulate how they considered evidence from nonmedical sources, are within the Commissioner of Social Security's broad authority and are not arbitrary and capricious. Consequently, the ALJ did not err in discounting Sato's evidence without explanation. The court resolved all other issues in a concurrently filed memorandum disposition. View "HUDNALL V. DUDEK" on Justia Law

The plaintiff filed two successive applications for disability benefits under Title XVI of the Social Security Act. Her first application, alleging disability beginning June 24, 2017, was denied by an Administrative Law Judge (ALJ) on September 18, 2018. While appealing this denial to the district court, she filed a second application for benefits for a later period. Washington State Disability Determination Services (DDS) reviewed the second application and awarded benefits, determining she was disabled starting September 19, 2018, the day after the ALJ denied her first application.The district court partially ruled in her favor on the first application and remanded it for further proceedings. The Appeals Council remanded the case to the ALJ with instructions. On June 23, 2021, the ALJ reopened the second application and denied the benefits previously granted by DDS. The ALJ concluded that the plaintiff was disabled beginning July 14, 2020, on her first application. The district court held it lacked jurisdiction to review the ALJ’s reopening and denial of benefits on the second application.The United States Court of Appeals for the Ninth Circuit reversed the district court’s decision, holding that the district court had jurisdiction to review the ALJ’s reopening of the second application. The Appeals Council did not reopen the second application, and the ALJ’s reopening occurred more than two years after the award, which is only permissible in cases of fraud or similar fault. Finding no evidence of fraud or similar fault, the Ninth Circuit held that the ALJ erred in reopening and reversing the award of benefits on the second application. The court remanded for the district court to direct the agency to award benefits according to DDS’s decision. The Ninth Circuit affirmed the district court’s decision on the first application, concluding that the ALJ’s finding that the plaintiff was not disabled between June 24, 2017, and September 19, 2018, was supported by substantial evidence. View "NEVIN V. COLVIN" on Justia Law

M.N. filed a due process complaint alleging that the District committed procedural and substantive violations of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400(d)(1)(A). The ALJ denied all claims and the district court affirmed. The Ninth Circuit filed an amended opinion reversing the district court's judgment, holding that neither the duration of the hearing, the ALJ's active involvement, nor the length of the ALJ's opinion can ensure that the ALJ was thorough and careful in its findings of fact; plaintiffs' claim that the District committed a procedural violation of the IDEA by failing to adequately document its offer of the visually impaired (TVI) services was not waived; the District committed two procedural violations as to the individualized education plan (IEP); the District's failure to specify the assistive technology (AT) devices that were provided infringed M.N.'s opportunity to participate in the IEP process and denied the student a free appropriate education (FAPE); the panel remanded for a determination of the prejudice the student suffered as a result of the District's failure to respond to the complaint and the award of appropriate compensation; in regard to substantive violations, the panel remanded so the district court could consider plaintiffs' claims in light of new guidance from the Supreme Court in Endrew F. v. Douglas Cty. Sch. Dist., 137 S. Ct. 988 (2017); and M.N., as the prevailing party, was entitled to attorneys' fees. View "M.C. v. Antelope Valley Union High School District" on Justia Law

The Ninth Circuit affirmed the denial of plaintiff's application for attorney fees under the Equal Access to Justice Act (EAJA), 28 U.S.C. 2412(d)(1)(A), holding that the Commissioner's litigation position was substantially justified. Plaintiff had successfully challenged the Commissioner's denial of her application for disability benefits and obtained a remand of her claim to the agency for further consideration. In this case, the district court did not abuse its discretion in determining that the Commissioner's position was substantially justified because the Commissioner's opposition to remand the claim on the merits was reasonable, even though it turned out to be unsuccessful. Finally, plaintiff's new evidence, though sufficient in the end to persuade the district court to remand the case, did not make that the only reasonable result. View "Decker v. Berryhill" on Justia Law