Justia Public Benefits Opinion Summaries

Arc challenged state officials' implementation of three new policies relating to state funding of home- and community-based services to developmentally disabled persons. California has reduced its funding for this program, as it has for other Medicaid-funded programs, 42 U.S.C. 1396-1396w-5, at various times. The court held that the district court abused its discretion in denying Arc's motion for a preliminary injunction because it misconstrued the Medicaid Act and applied deference to a federal agency decision where none was due; the court asserted pendant appellate jurisdiction over the dismissal of Arc's Medicaid Act claims, which relied on exactly the same reasoning, and reversed; the court could not go beyond correcting the district court's statutory interpretation to determining the propriety of preliminary injunctive relief; the primary state statute Arc challenges expired while the case was on appeal and, therefore, that challenge is moot; while the two other challenged statutes - the uniform holiday schedule and half-day billing rule - remain in effect, their impact was not the focus of the preliminary injunction proceeding and, therefore, the court remanded to allow augmentation of the record and reconsideration of the propriety of injunctive relief in the changed circumstances, applying the correct irreparable harm analysis.View "The Arc of California v. Douglas" on Justia Law

Plaintiff appealed the denial of his application for disability insurance benefits (SSI) based on his post traumatic stress disorder, arthritis, headaches, hearing problems, back and knee problems, and acid reflux. The court concluded that the ALJ did not err in denying plaintiff benefits because the ALJ's decision was supported by substantial evidence on the record. View "Smith v. Colvin" on Justia Law

Plaintiff appealed the district court's denial of her application for supplemental security income benefits (SSI) based on her mental impairment. The court concluded that the record was not fully developed as to plaintiff's mental impairments. Accordingly, the court reversed and remanded for further development of the record. The ALJ shall reschedule plaintiff for an IQ test and other testing he deems appropriate before ruling on plaintiff's claim for benefits.View "Channell v. Colvin" on Justia Law

Gienapp worked at Harbor Crestnursing care facility. In January 2011 she told Chattic, its manager, that she needed leave to care for her daughter, who was being treated for thyroid cancer. Chattic granted leave under the Family and Medical Leave Act, 29 U.S.C. 2612(a)(1). While on leave, Gienapp submitted an FMLA form, leaving blank a question about the leave’s expected duration. Harbor Crest did not ask her to fill in the blank, nor did it pose written questions as the 12-week period progressed. A physician’s statement on the form said that the daughter’s recovery was uncertain, and that if she did recover she would require assistance at least through July 2011. Chattic inferred from this that Gienapp would not return by April 1, her leave’s outer limit, and hired a replacement. When Gienapp reported for work on March 29, Chattic told her that she no longer had a job. The district court entered summary judgment, ruling that Gienapp had forfeited her FMLA rights by not stating exactly how much leave she would take. The Seventh Circuit reversed. Gienapp could not give a firm date; Department of Labor regulations call her situation “unforeseeable” leave, governed by 29 C.F.R. 825.303, which does not require employees to tell employers how much leave they need. View "Gienapp v. Harbor Crest" on Justia Law

This case involved a petition for injunctive and declaratory relief brought by plaintiffs Harbor Homes, Inc. and Gary Dube, Thomas Taylor, Cynthia Washington, and Arthur Furber against defendants the New Hampshire Department of Health and Human Services (DHHS), the Commissioner of DHHS, the Associate Commissioner of DHHS, and the Administrator of the Bureau of Behavioral Health seeking, in part, to enjoin DHHS from denying the individual plaintiffs the right to obtain Medicaid-funded services from their chosen provider, Harbor Homes. The individual plaintiffs received Medicaid-funded rehabilitative services from Harbor Homes. Since 1991, Harbor Homes participated in New Hampshire's Medicaid program pursuant to a Medicaid Provider Enrollment Agreement. On June 23, 2008, Harbor Homes entered into an interagency agreement (IAA) with a community mental health program, Community Council of Nashua, NH, now known as Greater Nashua Mental Health Center (GNMHC), which authorized Harbor Homes to provide certain Medicaid-funded rehabilitative services to GNMHC patients. In February 2011, Harbor Homes learned that GNMHC did not intend to renew its IAA and that the Medicaid reimbursable services provided by Harbor Homes would be transitioned to GNMHC. This was done pursuant to Administrative Rule He-M 426.04(a)(2), which meant that Harbor Homes would no longer have an IAA with a community mental health provider, and it would no longer be permitted to provide Medicaid funded mental health services to approximately one hundred and forty of its clients, including the individual plaintiffs in this case. Plaintiffs filed a petition for injunctive and declaratory relief, seeking a court order enjoining DHHS from "terminating or limiting Harbor Homes' status as a qualified Medicaid provider" and to direct the State to allow the individual plaintiffs to obtain community mental health services from Harbor Homes, the provider of their choice. Following two hearings, the court denied the plaintiffs' request for a preliminary injunction. Thereafter, all parties moved for partial summary judgment on the plaintiffs' claim that DHHS's reliance upon the IAA requirement as a reason to terminate Harbor Homes' status as a qualified Medicaid provider was improper because the requirement was invalid both on its face and as applied in this case. Plaintiffs appealed rulings of the Superior Court that denied their summary judgment motions and granting the defendants' cross-motions for summary judgment on two counts in the plaintiffs' petition. Upon review of the matter, the Supreme Court reversed the Superior Court's ruling that New Hampshire Administrative Rules, He-M 426.04(a)(2) did not violate the federal Medicaid Act. The case was remanded for further proceedings. View "Dube v. New Hampshire Dept. of Health & Human Svcs." on Justia Law

Robert Campbell quit his job as a school teacher in anticipation of accompanying his wife to Finland on her Fulbright grant. Campbell applied for unemployment benefits for the months between his resignation in June 2010 and his family's planned departure in February 2011. His request was denied because the Department of Employment Security determined that Campbell did not qualify for benefits as claimed under RCW 50.20.050(2)(b)(iii), known as the "quit to follow" provision. On appeal, the superior court reversed, but the Court of Appeals reinstated the agency action. The Supreme Court affirmed the Court of Appeals and held that Campbell's resignation from his job seven months before the planned relocation was not reasonable as contemplated by the statute.View "Campbell v. Dep't of Emp't Sec." on Justia Law

Plaintiff appealed the district court's denial of his motion for attorney's fees under the Equal Access to Justice Act, 28 U.S.C. 2412(d)(1)(A). The court affirmed the district court's determination that, although plaintiff prevailed in his lawsuit against the Commissioner, attorney's fees were unwarranted because the Commissioner had pursued a substantially justified position. Despite the oddity of the Commissioner's original position, his misstep did not merit a fee award.View "Meyer, III v. Astrue" on Justia Law

Wilson served in the Navy 1986-1990 and again 1992-1994. He was given a 70% disability rating for several service-connected physical conditions. In 2001, Wilson was found guilty of attempted first degree murder and aggravated battery with a firearm and was sentenced to concurrent life terms. His convictions and sentences were affirmed. Wilson then pursued unsuccessful state and federal collateral attacks. For veterans who have service-connected disabilities rated at 20% or more and who are incarcerated for than 60 days for a felony,” 38 U.S.C. 5313(a)(1) requires reduction in compensation to the level of 10% disability, effective the 61st day of incarceration. The VA informed Wilson by letter that his rate of compensation would be reduced to 10%, effective back to December 20, 2001 and requested refund of overpayment of $15,464.50. The Regional Office Committee on Waivers and Compromises denied a waiver. Wilson was also denied a “total disability evaluation based on individual unemployability due to service-connected disabilities” (TDIU) rating on the basis that his unemployability was due to his incarceration The Board of Veterans’ Appeals applied the multi-factor test from 38 C.F.R. 1.965 to determine that recovery of the overpayment would not be against “equity and good conscience” and agreed that Wilson was not entitled to a TDIU rating. The Veterans Court affirmed. The Federal Circuit upheld the decision.View "Wilson v. Gibson" on Justia Law

Plaintiff’s spouse (Spouse) applied to the Commissioner of Social Services (Department) for Medicaid benefits. After a review of the combined assets of both Spouse and Plaintiff, the Department concluded that Spouse was not eligible to receive Medicaid benefits. A hearing officer denied Plaintiff’s appeal, as did the superior court. The Supreme Court affirmed, holding that the trial court correctly concluded that the Department did not act arbitrarily or abuse its discretion in finding that the Department applied the correct eligibility and availability of assets criteria when evaluating the application for Medicaid benefits submitted by Spouse. View "Palomba-Bourke v. Comm’r of Soc. Servs." on Justia Law

Plaintiff appealed the district court's order affirming the ALJ's determination that he was not entitled to disability benefits or supplemental security income. The court concluded that the ALJ's determination that plaintiff retained the residual functioning capacity to return to work as a truck driver was supported by substantial evidence. Because the ALJ did not proceed to step five of the five-step sequential process for evaluating disability claims on remand, vocational expert testimony was not required. Accordingly, the court affirmed the judgment of the district court.View "Hill v. Colvin" on Justia Law