Justia Public Benefits Opinion Summaries

A neurologist submitted a Freedom of Information Act (FOIA) request to the United States Social Security Administration (SSA) seeking documents about how the SSA evaluates disability claims for migraines and other headache disorders. The SSA determined that this request was not directly related to the administration of any of its benefit programs. Relying on a provision in the Social Security Act (42 U.S.C. § 1306(c)), the SSA required the requester to pay the full cost of processing the request, which totaled $2,908. The requester paid the fee but later objected because the SSA did not respond within the statutory deadline set by FOIA.The United States District Court for the District of Vermont found in favor of the requester. The district court concluded that FOIA’s provision prohibiting fees when the agency fails to respond on time superseded the Social Security Act’s cost-reimbursement clause. As a result, the court ordered the SSA to refund the fee and awarded the requester attorneys’ fees and costs. The court reasoned that allowing the SSA to charge fees despite late responses would undermine the FOIA amendments designed to ensure agency timeliness.On appeal, the United States Court of Appeals for the Second Circuit considered whether the Social Security Act’s cost-reimbursement provision or FOIA’s fee-preclusion provision controlled. The Second Circuit held that the plain language of § 1306(c), which begins with a “notwithstanding” clause, explicitly exempts the SSA from FOIA’s fee rules for requests not directly related to program administration. The court agreed with the SSA’s determination that the request was not program-related and found the statute unambiguous. Therefore, the court reversed the district court’s judgment and vacated the award of attorneys’ fees and costs. View "Shapiro v. U.S. Soc. Sec. Admin." on Justia Law

The plaintiff, a former security guard, began experiencing panic attacks and anxiety, particularly when using public transportation, which ultimately led to the loss of his job. He was treated with medication, but continued to suffer from symptoms that interfered with his ability to work consistently. He applied for Supplemental Security Income and Social Security Disability Insurance, claiming disability from the time he was terminated due to his condition. The record included testimony from the plaintiff, a vocational expert, and five medical professionals, all of whom opined that he had at least moderate limitations in maintaining concentration, staying on task, and regular work attendance.After an initial denial by the Social Security Administration, the plaintiff requested a hearing before an Administrative Law Judge (ALJ). The ALJ found that the plaintiff had severe impairments but did not meet the criteria for a listed disability. Relying on some aspects of one consultative psychiatrist's opinion, and discounting others, the ALJ concluded that the plaintiff retained the residual functional capacity (RFC) to perform unskilled work in a goal-oriented setting, without finding any specific limitations on his ability to stay on task or maintain regular attendance. The vocational expert testified that an individual who was off task more than 10% of the workday or absent more than one day per month would be unable to maintain employment. The ALJ nonetheless found the plaintiff not disabled. The Appeals Council denied review, making the ALJ's decision final. The United States District Court for the Southern District of New York affirmed the denial.The United States Court of Appeals for the Second Circuit reviewed the administrative record de novo and concluded that the ALJ’s RFC finding was not supported by substantial evidence, particularly given the unanimous medical opinions regarding the plaintiff's limitations and the vocational expert’s testimony. The Second Circuit vacated the district court’s judgment and remanded the case to the Commissioner for further development of the record and reconsideration of the plaintiff’s application. View "Nunez v. Commissioner of Social Security" on Justia Law

Plaintiff-Appellant Mollie Marie Flinton applied for Social Security disability insurance and supplemental security income benefits in August 2015, citing mental health disabilities. Her application was initially denied, and she requested an administrative hearing. ALJ Mark Solomon, who was not properly appointed at the time, conducted the hearing and denied her benefits in March 2018. Flinton appealed, and the United States District Court for the Southern District of New York remanded the case for a new hearing in 2020. Despite the remand, Flinton appeared again before ALJ Solomon in August 2021, whose appointment had been ratified by then.The United States District Court for the Southern District of New York, presided over by Magistrate Judge Gary R. Jones, granted a motion for judgment on the pleadings in favor of the Commissioner of Social Security in September 2023. The court found that the ALJ’s decision was supported by substantial evidence and that remanding the case to a new ALJ was unnecessary, despite acknowledging the Appointments Clause challenge.The United States Court of Appeals for the Second Circuit reviewed the case and held that, pursuant to Lucia v. SEC, Flinton was entitled to a new hearing before a different, properly appointed ALJ. The court found that ALJ Solomon’s initial decision was invalid due to his improper appointment and that the subsequent hearing before the same ALJ did not cure the constitutional violation. The court vacated the district court’s decision and remanded the case to the Commissioner for a de novo hearing before a different, validly appointed ALJ. View "Flinton v. Comm'r of Soc. Sec." on Justia Law

Plaintiff, on behalf of herself and her son, K.T., filed suit under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., against the DOE. At issue is the adequacy of three individualized education programs (IEP), which were characterized by a pattern of procedural violations of the IDEA committed by the DOE, and whether these errors deprived K.T. of a free appropriate public education (FAPE) for a period of three consecutive years. The court concluded that the procedural violations in formulating each IEP, when taken together, deprived K.T. of a FAPE for each school year. The DOE displayed a pattern of indifference to the procedural requirements of the IDEA and carelessness in formulating K.T.’s IEPs over the period of many years, repeatedly violating its obligations under the statute, which consequently resulted in the deprivation of important educational benefits to which K.T. was entitled by law. Accordingly, the court reversed the judgment of the district court and remanded for further proceedings. On remand, the district court is directed to consider, in the first instance, what, if any, relief plaintiff is entitled to as an award for K.T.'s FAPE deprivations. View "L.O. ex rel. K.T. v. N.Y.C. Dep’t of Educ." on Justia Law

Plaintiff filed a class action against the Commissioner, challenging New York’s coverage restrictions on certain medical services provided under its Medicaid plan. Plaintiffs argued that New York’s 2011 plan amendments, which restrict coverage of orthopedic footwear and compression stockings to patients with certain enumerated medical conditions, violate the Medicaid Act’s, 42 U.S.C. 1396 et seq., reasonable standards, home health services, due process, and comparability provisions, as well as the anti‐discrimination provision and integration mandate of Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12131 et seq., and section 504 of the Rehabilitation Act, 29 U.S.C. 794. Because neither the Medicaid Act nor the Supremacy Clause confers a private cause of action to enforce the reasonable standards provision, the court vacated the district court’s grant of summary judgment to plaintiffs on that claim; the court declined to reach plaintiffs’ unequal treatment claim under the ADA and Rehabilitation Act as largely duplicative of their integration mandate claim; and the court affirmed the summary judgment rulings with respect to the remaining claims. Defendant is entitled to summary judgment on plaintiffs' home health services plan because orthopedic footwear and compression stockings constitute optional “prosthetics” rather than mandatory “home health services” under the Medicaid Act; defendant is entitled to summary judgment on the hearing element and plaintiffs are entitled to summary judgment on the notice element of plaintiffs’ due process claim, because the due process provision required New York to provide plaintiffs with written notice – though not evidentiary hearings – prior to terminating their benefits; plaintiffs are entitled to summary judgment on their comparability provision claim because New York’s coverage restrictions deny some categorically needy individuals access to the same scope of medically necessary services made available to others; and plaintiffs are entitled to summary judgment on their anti‐discrimination claims because New York’s restrictions violate the integration mandate of the ADA and Rehabilitation Act. Finally, the court vacated the injunction and remanded for further consideration on the appropriate relief because the injunction is broader than is warranted by the court's liability conclusions. View "Davis v. Shah" on Justia Law

Binder, a law firm representing claimants before the SSA, appealed from summary judgment in two related cases where Binder seeks past attorney's fees. When Binder sought to hold the SSA liable for the fees, the district courts granted summary judgment to the SSA on the basis of sovereign immunity. The court affirmed the judgments and held that, regardless of the SSA’s statutory duties to withhold attorney’s fees from payments to successful claimants, there is no waiver of sovereign immunity in 42 U.S.C. 406(a) that would permit Binder’s lawsuits for money damages. View "Binder & Binder v. Colvin" on Justia Law

The Department appealed a judgment awarding plaintiffs reimbursement under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., for one year of private school education for their daughter, L.K. The court concluded that the Department’s refusal to discuss the bullying of L.K. with her parents during the process of developing L.K.’s individualized education program (IEP), violated the IDEA. The court also concluded that plaintiffs have met their burden to show that their choice of a private placement for L.K. was appropriate and that the equities favored reimbursing them. Accordingly, the court affirmed the judgment. View "T.K. v. N.Y.C. Dept. of Educ." on Justia Law

Plaintiff appealed the denial of social security disability benefits, alleging that the Appeals Council erred by failing to provide an explanation for why it disregarded the treating physician’s opinion and that the ALJ’s decision is not supported by substantial evidence in light of a treating physician’s opinion. The court agreed and held that, based on the record, including the physician's opinion, the ALJ's determination is not supported by substantial evidence in the record. Accordingly, the court vacated the judgment and remanded for further proceedings. View "Lesterhuis v. Colvin" on Justia Law