Justia Public Benefits Opinion Summaries

Articles Posted in US Court of Appeals for the Eighth Circuit
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Plaintiffs filed suit under the Individuals with Disabilities Education Act (IDEA), bringing a due process challenge to the school district's individualized education plan (IEP) and school placement before the Missouri Administrative Hearing Commission. The Commission affirmed the plan and placement, denying reimbursement. The district court reversed the Commission but limited the reimbursement award based on equitable considerations. The Eighth Circuit held that the school district violated the IDEA and the district court erred in limiting the award. As a preliminary matter, the court held that the school district's jurisdictional challenge was without merit; the school district's mootness challenge also failed; and the district court properly placed the burden on plaintiffs in the proceeding before it and correctly stated the standard of review on appeal. On the merits, the court held that the school district denied plaintiffs' son a free and appropriate education as required by the IDEA when it placed him at a school without direct occupational therapy or a sensory diet plan in place to address his autism-related issues. The court also held that an award limitation based on improvements to the school was inappropriate and inconsistent with the purposes of the IDEA because the school district failed to give any notice to plaintiffs. Furthermore, limiting an award based on improvements not communicated to plaintiffs was inconsistent with the IDEA's purpose. Accordingly, the court reversed the district court's limitation of tuition reimbursement and awarded full tuition reimbursement. View "D. L. v. St. Louis City School District" on Justia Law

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The Eighth Circuit affirmed the district court's denial of supplemental security income to claimant, who suffers from borderline intellectual functioning, learning delays, schizoaffective disorder, mood disorder, personality disorder, and an anxiety disorder. The court held that substantial evidence supported the ALJ's determination that claimant was not disabled within the meaning of the social security guidelines and listings regardless of which Section 12 mental disorder listing was considered. View "Cronin v. Saul" on Justia Law

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The Eighth Circuit affirmed the denial of social security disability insurance benefits and supplemental security income to plaintiff. The court held that substantial evidence supported the ALJ's conclusion that plaintiff's work as a receptionist constituted "substantial gainful activity." In this case, she worked predominately as a receptionist, was paid for the work, and performed work that plainly involved significant physical or mental activities. The court held that plaintiff performed activities beyond her core duties as a receptionist only occasionally, and her responsibilities as a receptionist alone constituted substantial gainful activity. View "Sloan v. Saul" on Justia Law

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The Eighth Circuit affirmed the denial of social security disability benefits to plaintiff. The court held that plaintiff clearly suffered from back pain, but substantial evidence supported the ALJ's finding that plaintiff had the residual functional capacity to perform light work. Furthermore, the ALJ did not err by failing to order a consultative examination, because the evidence in the record provided a sufficient basis for the ALJ's decision, and substantial evidence supported the ALJ's credibility determination on the record as a whole. View "Swink v. Saul" on Justia Law

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The Eighth Circuit affirmed the denial of plaintiff's application for supplemental security income, holding that substantial evidence supported the ALJ's determination that plaintiff had only a moderate restriction on his activities of daily living. In this case, while the ALJ could have weighed the evidence differently, substantial evidence supported the ALJ's determination that the psychological expert's review of all the evidence should be credited over the counselor's observations as a non-medical, other source. View "Dols v. Saul" on Justia Law

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The Eighth Circuit affirmed the denial of social security disability insurance benefits and supplemental security income (SSI) benefits to claimant. The court held that substantial evidence supported the ALJ's findings that claimant's physical and mental impairments did not meet or equal the severity of any of the listed impairments. Furthermore, substantial evidence supported the ALJ's residual functioning capacity determination and the mental limitations included in that finding. The court also held that the vocational expert's testimony did not conflict with the Dictionary of Occupational Titles and the ALJ was entitled to rely on the expert's testimony. View "Twyford v. Commissioner" on Justia Law

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The Eighth Circuit affirmed the denial of social security disability benefits to claimant, holding that the denial of benefits was supported by substantial evidence. The court held that the ALJ did not err in determining claimant's Residual Functional Capacity and did not err in determining that the medical records did not support the limitations stated by her treating physician. The court also held that the ALJ did not err by discrediting the physician's testimony to the extent that it exceeded the supported limitations. View "Despain v. Berryhill" on Justia Law

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The Eighth Circuit affirmed the denial of disability insurance benefits to claimant. The court held that the agency was justified in reopening claimant's case based on new and material information; there was no due process violation and claimant had adequate notice that the reopened proceedings could result in a determination that she was not disabled; res judicata did not bar the Commissioner from revising a determination; substantial evidence supported the ALJ's determination that claimant was not disabled from 2012 onward; claims of witness and evidentiary errors rejected; the ALJ did not err in determining that claimant could perform her past relevant work; and there was no error in the ALJ's statement regarding claimant's residual functional capacity (RFC) to the vocational expert where substantial evidence supported the omission of certain limitations from her RFC. View "Schwandt v. Berryhill" on Justia Law

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The Eighth Circuit affirmed the district court's dismissal of plaintiff's action challenging the denial of his application for disability insurance benefits. The court held that plaintiff was not entitled to equitable tolling of the time limit, because no extraordinary circumstance prevented him from timely filing an action in the district court. In this case, plaintiff's failure to file his appeal despite clear, repeated instructions that he should do so, was at best a garden variety claim of excusable neglect for which equitable tolling was unavailable. Therefore, plaintiff's action was time-barred and was properly dismissed by the district court. View "Thompson v. Commissioner of Social Security Administration" on Justia Law

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The Eighth Circuit affirmed the denial of disability benefits to plaintiff based on his claim of mild intellectual disability, low education, slow learning abilities, and memory problems. The court held that substantial evidence supported the ALJ's assessment that plaintiff was only moderately intellectually limited, rather than intellectually disabled. Consequently, the court also held that plaintiff's claim that the ALJ failed to consider whether plaintiff met the criteria for intellectual disability was meritless. View "Bagwell v. Commissioner" on Justia Law