Justia Public Benefits Opinion Summaries

During a contentious divorce and custody dispute, Amanda Hovanec, who had returned to Ohio from South Africa with her children, conspired with Anthony Theodorou, her romantic partner, to kill her husband, T.H. After failed attempts to hire hitmen in South Africa, Theodorou, at Hovanec’s direction, obtained and shipped etorphine, a dangerous animal tranquilizer, to the United States. Hovanec ultimately used the drug to fatally inject T.H. at her mother Anita Green’s home. Green assisted after the murder by helping to select a burial site, driving the others to dig a grave, and later transporting them and the body for burial. The group also undertook efforts to conceal the crime, including disposing of T.H.’s belongings and misleading authorities. All three were arrested after an investigation revealed dashcam footage of the crime.In the United States District Court for the Northern District of Ohio, Hovanec pleaded guilty to multiple controlled-substance offenses resulting in death, and Green pleaded guilty to being an accessory after the fact. Hovanec received a 480-month sentence; Green received 121 months and was ordered to pay restitution for psychological care for T.H.’s and Hovanec’s children. Both defendants appealed their sentences and, in Green’s case, the restitution order.The United States Court of Appeals for the Sixth Circuit affirmed the sentences for both Hovanec and Green. The appellate court upheld the denial of a sentencing reduction for Green based on her lack of candor regarding knowledge of the murder plan. The court also affirmed the sentencing enhancements for Hovanec’s leadership role and obstruction of justice. However, the court reversed the restitution order against Green, holding that under federal law, restitution for psychological care requires evidence of bodily injury, defined as physical harm or physical manifestations of psychological harm, and remanded for further factual findings on this issue. View "United States v. Green" on Justia Law

The plaintiff applied for disability benefits from the Social Security Administration (SSA) but was denied at the agency level. She then sought judicial review in the United States District Court for the Northern District of Ohio. After the Commissioner of Social Security reviewed the case further, the Commissioner moved to remand the matter to the Administrative Law Judge (ALJ) for additional proceedings, specifically for further articulation regarding the persuasiveness of the evidence and further consideration of medical opinions. The Commissioner did not argue that the ALJ committed reversible error. The plaintiff agreed to a remand but requested that the court issue instructions to award her benefits outright.The district court granted the Commissioner’s motion for remand, reasoning that factual disputes remained and that it was not prepared to award benefits. The court remanded the case to the SSA for further consideration without affirming, modifying, or reversing the ALJ’s decision, and without expressly finding reversible error or making the specific predicate findings required for a remand under Sentence Six of 42 U.S.C. § 405(g). The plaintiff appealed the district court’s order.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that a district court may not remand a Social Security case under Sentence Four of 42 U.S.C. § 405(g) without explicitly affirming, modifying, or reversing the decision of the ALJ. The appellate court found that the district court’s order failed to comply with the requirements of either Sentence Four or Sentence Six and that district courts do not have inherent authority to issue other types of remand orders in Social Security cases. The Sixth Circuit therefore vacated the district court’s order and remanded the matter for further proceedings consistent with the opinion. View "Follen v. Commissioner of Social Security" on Justia Law

A group of Black farmers and their association, along with several individual members, sought to file claims with the U.S. Department of Agriculture (USDA) for financial assistance under a program created by the Inflation Reduction Act of 2022. They wished to submit applications on behalf of deceased relatives who had allegedly experienced discrimination in USDA farm lending programs. The USDA, however, had a policy that excluded applications reporting only discrimination against individuals who were deceased at the time of application, making such claims ineligible for the program.The plaintiffs filed suit in the United States District Court for the Western District of Tennessee, seeking an injunction to require the USDA to accept these “legacy claims.” The district court denied their motion for a preliminary injunction and granted the government’s motion to dismiss under Rule 12(b)(6), holding that the relevant statute only authorized financial assistance to living farmers. The plaintiffs appealed this decision to the United States Court of Appeals for the Sixth Circuit and also sought an emergency injunction pending appeal, which was denied.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The appellate court held that the statutory language of § 22007(e) of the Inflation Reduction Act required the USDA to provide “assistance” to farmers who experienced discrimination, and that “assistance” was forward-looking and could not be provided to deceased individuals. The court found that the statute did not authorize compensation for past harm to deceased farmers, distinguishing “assistance” from “compensation.” The court affirmed the district court’s judgment and denied the motion for an injunction pending appeal as moot, holding that the USDA was required to reject applications filed on behalf of deceased farmers. View "Black Farmers & Agriculturalists Ass'n v. Rollins" on Justia Law

In 1994, Kenneth Hayes was murdered in Wayne County, Michigan. Larry Smith was convicted of first-degree murder and a firearm charge, largely based on the testimony of Edward Allen, a jailhouse informant who claimed Smith confessed to the crime. Smith’s conviction was affirmed on direct appeal, and his subsequent state and federal habeas petitions were unsuccessful. Years later, the Wayne County Prosecutor’s Conviction Integrity Unit investigated and found evidence suggesting Allen’s testimony may have been fabricated as part of a broader scheme involving police and prosecutors eliciting false testimony from informants. Smith’s conviction was vacated in 2021, and he was released from prison.After his release, Smith obtained compensation from the State of Michigan under the Wrongful Imprisonment Compensation Act (WICA), settling for $850,000 and signing a release of claims against the State. He then filed a federal lawsuit against Wayne County and prosecutor Robert Donaldson, alleging constitutional violations under 42 U.S.C. § 1983 and a Monell claim against the County for policies encouraging false testimony. The United States District Court for the Eastern District of Michigan granted summary judgment to both defendants, finding Donaldson was protected by absolute prosecutorial immunity and that Smith’s settlement under WICA released his claims against Wayne County.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. It held that Donaldson was entitled to absolute prosecutorial immunity because his conduct—preparing a witness for trial—was within the scope of his advocacy role, not investigatory. The court also held that Smith’s acceptance of the WICA settlement released all claims against Wayne County, including federal claims, as a matter of law. The Sixth Circuit affirmed the district court’s grant of summary judgment to both defendants. View "Smith v. Wayne County" on Justia Law

Jaime Norris applied for social security disability benefits and supplemental security income in October 2020, claiming disability due to various mental and physical disorders. The Social Security Administration denied his claim, leading Norris to request a hearing before an administrative law judge (ALJ). During the hearing, both Norris and a vocational expert testified. The ALJ concluded that Norris was not disabled under the Social Security Act, determining that he could adjust to other jobs existing in significant numbers in the national economy. Norris appealed to the Appeals Council, which denied his request for review, finalizing the ALJ's decision.Norris then sought judicial review in the United States District Court for the Northern District of Ohio. The district court affirmed the ALJ's decision, finding that substantial evidence supported the ALJ's conclusion. Norris subsequently appealed to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit reviewed whether the ALJ applied the correct legal standards and whether the findings were supported by substantial evidence. The court affirmed the ALJ's decision, holding that the vocational expert's testimony about the number of jobs available in the national economy constituted substantial evidence. The court rejected Norris's arguments that the ALJ erred in determining the number of significant jobs and that the district court improperly shifted the burden of proof. The court concluded that the ALJ's findings were reasonably drawn from the record and supported by substantial evidence, even if the evidence could support a contrary decision. View "Norris v. Commissioner of Social Security" on Justia Law

Debra Tucker applied for disability insurance benefits under Title II of the Social Security Act in 2018. After multiple denials at the administrative level, she appealed to the federal district court. In 2023, the district court reversed the final administrative decision of the Commissioner of Social Security, remanding Tucker’s claim for further administrative proceedings. The district court awarded Tucker’s attorney $7,500 in attorney’s fees under the Equal Access to Justice Act (EAJA), along with $402 in costs. Tucker’s attorney had a contingency-fee agreement for twenty-five percent of any past-due benefits awarded. In August 2024, an administrative law judge found Tucker disabled and granted her monthly disability benefits retroactive to February 2018, totaling $124,821.70 in past-due benefits.The district court granted in part and denied in part the attorney’s motion for $31,205.43 in fees under 42 U.S.C. § 406(b), awarding $17,400 instead. The court found the requested fee excessive, amounting to a windfall, and set an imputed hourly rate of $500. The attorney’s motion for reconsideration, reducing the fee request to $22,620, was denied. The attorney appealed, seeking the full $31,205.43.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court found that the district court properly started with the contingency-fee agreement and then tested it for reasonableness, considering the effective hourly rate and other factors. The district court did not misapply the law by comparing the effective hourly rate to the EAJA rate and the attorney’s ordinary rate. The appellate court affirmed the district court’s decision, concluding that it acted within its discretion in reducing the fee to avoid a windfall. View "Tucker v. Commissioner of Social Security" on Justia Law

Paula S. Linden applied for Social Security benefits online in September 2014 at the age of 62, which was before her full retirement age of 66. As a result, she received smaller monthly payments than she would have if she had waited until 66. Linden claimed that she applied early based on misinformation from the Social Security Administration (SSA), which allegedly told her that she would receive the same benefits as if she had applied at 66. She sought to have her benefits recalculated as if she had applied at 66.The SSA denied her request, both initially and upon reconsideration. An Administrative Law Judge (ALJ) also ruled against her, stating that the statutory provision she cited, 42 U.S.C. § 402(j)(5), only applied to individuals who failed to apply for benefits due to misinformation. The ALJ also found insufficient evidence that Linden received misinformation from the SSA. The Appeals Council denied her request for review. Linden then filed a complaint in the United States District Court for the Eastern District of Michigan, which granted summary judgment in favor of the SSA and denied Linden’s motion for summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the plain text of 42 U.S.C. § 402(j)(5) precluded Linden’s recovery because the statute only applies to individuals who failed to apply for benefits due to misinformation. Since Linden did apply for benefits, she did not meet the statutory requirement. The court also found that the SSA’s regulations supported this interpretation. Additionally, the court noted that even if there was misinformation, it would not change the outcome because Linden did not fail to apply for benefits. Therefore, the court affirmed the district court’s decision. View "Linden v. Comm'r of Soc. Sec." on Justia Law

Ken Lick Coal Company employed Bob Reed from 1973 to 1986, during which he was exposed to coal dust. Reed later worked for Green Valley Hydro Seeding & Reclamation and JPR, where he continued to be exposed to coal dust. Reed developed breathing problems and filed three claims for black-lung benefits. His first claim in 1986 was denied. His second claim in 2007 was initially granted but later denied by an administrative law judge who found Reed did not have pneumoconiosis. Reed's third claim in 2018 was pursued by his widow after his death.The district director awarded benefits and designated Ken Lick as the responsible operator. An administrative law judge upheld this decision, finding Reed had over 15 years of coal-mine employment, including his work with Green Valley and JPR. The judge also found that Ken Lick had stipulated to being the responsible operator during Reed's second claim, which the judge deemed binding in the third claim.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the administrative law judge erred in treating Ken Lick's prior stipulation as binding. The court found that the stipulation was a legal conclusion rather than a factual one, and thus, the judge had the authority to disregard it. The court noted that the administrative law judge would not have required Ken Lick to pay the benefits but for the stipulation. Consequently, the Sixth Circuit granted Ken Lick's petition for review and transferred the liability for Reed's claim to the Black Lung Disability Trust Fund. View "Ken Lick Coal Co. v. OWCP" on Justia Law

Donald Hunter, a former coal miner, applied for benefits under the Black Lung Benefits Act (BLBA) in 2019, claiming that he was totally disabled due to chronic obstructive pulmonary disease (COPD) caused by his coal mine employment. Southern Ohio Coal Company, his former employer, contested his claim, arguing that Hunter's COPD was caused by his significant history of smoking cigarettes rather than coal mine dust exposure.An Administrative Law Judge (ALJ) reviewed the case and awarded benefits to Hunter, finding that his COPD constituted legal pneumoconiosis and that it was a substantially contributing cause of his total disability. Southern Ohio Coal appealed to the Benefits Review Board (BRB), arguing that the ALJ erred in discrediting its evidence and in crediting Hunter's evidence. The BRB affirmed the ALJ's decision, holding that the ALJ had properly considered and weighed the evidence.The United States Court of Appeals for the Sixth Circuit reviewed the case. Southern Ohio Coal argued that the ALJ erred by relying on a pulmonary function test (PFT) that did not comply with regulatory quality standards and by relieving Hunter of his burden to establish entitlement to benefits. The court found that the ALJ acted within his discretion in determining that the PFT was compliant and supported Hunter's entitlement to benefits. The court also held that the ALJ did not improperly rely on regulatory guidance or flip the burden of proof to Southern Ohio Coal. The ALJ's decision was supported by substantial evidence, including expert opinions and Hunter's testimony.The Sixth Circuit denied the petition for review, affirming the ALJ's decision to award benefits to Hunter. The court held that the ALJ correctly applied the law and that his decision was supported by substantial evidence. View "Southern Ohio Coal Co. v. Office of Workers' Compensation Programs" on Justia Law

Edna Napier, a former cashier and certified nursing assistant, applied for disability insurance benefits due to severe physical conditions and mental impairments, including depression and anxiety. Her initial application was denied by the Social Security Administration (SSA) in 2018. Napier filed a new application in December 2019, claiming she had been unable to work since December 2018. An administrative law judge (ALJ) held an evidentiary hearing and concluded that Napier was not disabled under the Social Security Act, finding that her mental impairments were mild and her physical impairments did not prevent her from performing her past work as a cashier.The United States District Court for the Eastern District of Kentucky affirmed the ALJ's decision. Napier appealed, arguing that the ALJ erred in assessing the severity of her mental impairments and failed to account for them in her residual functional capacity (RFC) analysis.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the ALJ's decision was supported by substantial evidence and complied with proper legal standards. The ALJ had considered Napier's testimony, her limited treatment history for mental impairments, and the opinions of several psychologists. The ALJ found that Napier's mental impairments were not severe and that her physical impairments did not preclude her from performing her past work. The court also found that the ALJ adequately accounted for Napier's mental impairments in the RFC analysis.The Sixth Circuit affirmed the district court's judgment, concluding that the ALJ's findings were supported by substantial evidence and that the ALJ had followed the appropriate procedures in evaluating Napier's claims. View "Napier v. Commissioner of Social Security" on Justia Law