Justia Public Benefits Opinion Summaries

Plaintiff, who suffers from Ehlers-Danlos Syndrome, filed suit against the Department after it denied him "shelter needy" benefits, raising claims under 42 U.S.C. 1983; the Americans with Disabilities Act (ADA), 12 U.S.C. 12101 et seq.; and the Rehabilitation Act (RA), 29 U.S.C. 701 et seq. The court concluded that the appeal was timely, rejecting the district court's conclusion that plaintiff did not timely file notice and proof of service; concluded that the Rooker-Feldman doctrine is inapplicable to judicial review of executive action, including determinations made by a state administrative agency; and disagreed with the district court’s conclusion that section 256.045 of the Minnesota statutes prevented the court from exercising supplemental jurisdiction over the appeal from a state agency’s decision. In interpreting Minn. Stat. 256.045, subd. 7, the court concluded that subdivision 7 lays out one permissible route through which an aggrieved party may appeal from the Commissioner’s order and thus prevent it from becoming final, but it does not strip the federal court of its authority to hear the same appeal through the exercise of supplemental jurisdiction. Because the district court improperly concluded that it lacked jurisdiction based solely on the state statute, the district court failed to determine whether it should exercise supplemental jurisdiction under 28 U.S.C. 1367 or whether any abstention doctrine applied. Therefore, the court vacated the decision dismissing the supplemental state-law claim and remanded for further consideration. Because the state agency’s decision was not final, the district court erred by finding that plaintiff’s ADA and RA claims were precluded. Finally, the court agreed with the district court that plaintiff's allegations failed to state a due process or equal protection claim. Because plaintiff’s equal protection claim is predicated on the same allegations as his ADA and RA claims, the district court did not err by dismissing the section 1983 claim. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Wong v. Minnesota DHS" on Justia Law

Taskila, age 37, has several health issues. She was involved in serious car accidents in 1996, 2006, and 2010; underwent successful treatment in 2011 for a mass in her breast; and sought treatment for knee pain. She claims, the injuries have led to unremitting pain in her neck and back, to anxiety and depression, to memory problems, to incontinence, to carpal tunnel syndrome, to an inability to work. Taskila sought Social Security disability insurance and supplemental security income. An initial disability examiner denied her applications. After a hearing, an ALJ did the same. The appeals council denied review. The district court and Sixth Circuit affirmed, finding the denial supported by substantial evidence that Taskila could perform a significant number of jobs in the national economy. View "Taskila v. Comm'r of Social Sec." on Justia Law

Mission purchased the assets of South Coast and attempted by an assets-only purchase to avoid South Coast's potential liabilities under South Coast's Medicare provider agreement. These liabilities encompassed potential mandated reimbursement to Medicare for any previous overpayments made to South Coast. The Secretary determined that Mission was not entitled to bill Medicare for patient services at its new facility until that facility had a provider agreement of its own. Mission appealed the Secretary's decision. The court rejected Mission's assertion that former 42 C.F.R. 489.13(d)(1)(i) permitted it to avoid South Coast’s Medicare liabilities. The court cited to the Fifth Circuit's opinion in United States v. Vernon Home Health, Inc.: “federal law governs cases involving the rights of the United States arising under a nationwide federal program such as the Social Security Act. The authority of the United States in relation to funds disbursed and the rights acquired by it in relation to those funds are not dependent upon state law.” It is equally true that private parties have no power to alter their legal obligations with Medicare under their provider agreements. The court also rejected Mission's argument that it is entitled to the benefit of the retroactivity provision in 42 C.F.R. 489.13(d)(2). The court concluded that the Secretary's interpretations and decisions rendered by the DAB in this case were reasonable. Accordingly, the court affirmed the judgment. View "Mission Hosp. Reg'l Med. Ctr. v. Burwell" on Justia Law

Veterans’ Groups challenged regulations issued in 2014 by the Department of Veterans Affairs pursuant to its notice-and-comment rulemaking authority. The Final Rule amended the VA’s adjudication and appellate regulations to require that all claims for compensation “[f]or disability resulting from personal injury suffered or disease contracted in line of duty, or for aggravation of a preexisting injury suffered or disease contracted in line of duty . . . during a period of war” and related appeals originate on standard VA forms. The VA’s prior regulation provided that “[a]ny communication or action, indicating an intent to apply for . . . benefits[,] . . . may be considered an informal claim,” 38 C.F.R. 3.155(a). The Federal Circuit denied the petitions and found the Final Rule valid because it accords with applicable rulemaking procedures and is not arbitrary, capricious, an abuse of discretion, or otherwise contrary to law. The Rule does not contravene Congress’s mandate that the VA has a duty to develop veterans’ claims. View "Veterans Justice Grp., LLC v. Sec'y of Veterans Affairs" on Justia Law

Veterans’ Groups challenged regulations issued in 2014 by the Department of Veterans Affairs pursuant to its notice-and-comment rulemaking authority. The Final Rule amended the VA’s adjudication and appellate regulations to require that all claims for compensation “[f]or disability resulting from personal injury suffered or disease contracted in line of duty, or for aggravation of a preexisting injury suffered or disease contracted in line of duty . . . during a period of war” and related appeals originate on standard VA forms. The VA’s prior regulation provided that “[a]ny communication or action, indicating an intent to apply for . . . benefits[,] . . . may be considered an informal claim,” 38 C.F.R. 3.155(a). The Federal Circuit denied the petitions and found the Final Rule valid because it accords with applicable rulemaking procedures and is not arbitrary, capricious, an abuse of discretion, or otherwise contrary to law. The Rule does not contravene Congress’s mandate that the VA has a duty to develop veterans’ claims. View "Veterans Justice Grp., LLC v. Sec'y of Veterans Affairs" on Justia Law

Dover served in the Navy, 1956-1960, and, in 1968, filed a claim for service-connected disability benefits. His claim for a hand injury was denied; he did not appeal. In 2004, the VA regional office (RO) denied Dover's motion to reopen. In 2008, Dover requested clear and unmistakable error (CUE) review of both the 1968 decision and the 2004 refusal to reopen. In 2009, the RO granted service connection based on new medical evidence and assigned an effective date of March, 2006, the date of another request to reopen. In 2009, Dover appealed for an earlier effective date of 1968, but the RO found no CUE. In 2011, Dover provided more detailed arguments. The Board for Veterans’ Appeals issued a final ruling of no CUE. On appeal, the VA conceded that it erred by failing to dismiss Dover’s non-specific CUE claim. The Veterans Court remanded with instructions to allow and consider additional evidence and argument in support of the claim. The Board dismissed Dover’s 2008 claim without prejudice but treated the 2011 submission of additional arguments as a separate CUE claim and remanded to the RO. Dover moved under the Equal Access to Justice Act for attorney’s fees incurred on appeal, 28 U.S.C. 2412(d). The Veterans Court rejected the motion because it believed that its remand was for dismissal. The Federal Circuit reversed, stating that the remand expressly contemplated, and the appellant received, further proceedings, sufficient for prevailing party status. View "Dover v. McDonald" on Justia Law

Eilise was born in 1996 and had problems with gross motor skills and language development. After therapy, Eilise showed dramatic improvement. In 2001, Eilise received three vaccinations, including her second dose of the measles, mumps, and rubella vaccine. Five days later, Eilise’s brother witnessed her arching her back, thrusting her head back, rolling her eyes, and jerking. He did not know what was happening. Her parents, who did not witness the seizure, noted that Eilise was feverish and lethargic. Eilise had a grand mal seizure at school. She was taken to a hospital. She had another seizure there. Eilise’s MRI results were generally normal, but her EEG results were “consistent with a clinical diagnosis of epilepsy.” She continued to suffer seizures until she started a ketogenic diet. Her parents filed suit under the National Childhood Vaccine Injury Compensation Program, 42 U.S.C. 300aa, alleging that Eilise suffered from autism as a result of her vaccinations; they later amended to allege, instead, that Eilise suffered from a “seizure disorder and encephalopathy.” The Claims Court affirmed denial of her petition. The Federal Circuit vacated: in certain cases, a petitioner can prove a logical sequence of cause and effect between a vaccination and the injury with a physician’s opinion where the petitioner has proved that the vaccination can cause the injury and that the vaccination and injury have a close temporal proximity. View "Moriarty v. Sec'y of Health & Human Servs." 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

In 2012, Illinois enacted legislation requiring prior approval for reimbursement for more than four prescriptions for one Medicaid patient within a 30‐day period. 305 ILCS 5/5‐5.12(j). Ciarpaglini is an Illinois Medicaid recipient and suffers from chronic conditions, including bipolar disorder, attention deficit hyperactivity disorder, panic disorder, and generalized anxiety disorder. Doctors have prescribed at least seven medications to manage these conditions. Ciarpaglini alleges that after the prior‐approval requirement took effect, he could not, at least at times, obtain medications he needed and that he has contemplated committing suicide, committing petty crimes so that he would be jailed, or checking himself into hospitals just to get medications. He challenged the requirement under federal Medicaid law, the Americans with Disabilities Act, the Rehabilitation Act, and the Constitution. Illinois subsequently moved Ciarpaglini from the general fee‐for‐service Medicaid program to a new managed care program, under which the requirement does not apply. The district court dismissed the matter as moot. The Seventh Circuit remanded, finding insufficient evidence to determine whether the claims were moot, given Ciarpaglini’s stated desire to move to another county and the lack of information about whether the change in his program was individual or part of a change in policy. View "Ciarpaglini v. Norwood" 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