Justia Public Benefits Opinion Summaries

Plaintiffs Kenneth Bond and Deborah Thibault, on behalf of themselves and a class of others similarly situated, appealed a superior court order granting summary judgment to the defendants, the City of Manchester and Paul Martineau in his official capacity as Commissioner of the Manchester Welfare Department (collectively, the City). In January 2010, the plaintiffs applied for general assistance from the City pursuant to RSA chapter 165. See RSA 165:1, I (2002). On February 24, 2010, the City approved $140.00 per week in rental assistance. On March 18, 2010, the City suspended this assistance for seven days because of the plaintiffs' failure to provide certain documentation, including that which related to $30 the plaintiffs used to buy gas for a vehicle. The City lifted this suspension on March 25, 2010, noting that the plaintiffs were "unable to show compliance with the $30 purchase of vehicle gas that [they] stated [they] had previously purchased through an alternate financial resource." On April 9, 2010, the City revoked an April 8 voucher and denied the plaintiffs all assistance for six months because they had misrepresented information related to their vehicle. The plaintiffs petitioned the superior court to enjoin the City from suspending their assistance. Because the Supreme Court held that RSA 165:1-b and the Guidelines pertaining to rental assistance actually conflict, the Court reversed the trial court's grant of summary judgment in favor of the City and remanded the case for further proceedings.View "Bond v. Martineau" on Justia Law

Brian Ross had been absent from the State of Alaska since 1990, first as a student at the United States Naval Academy and later as a career Marine Corps officer. Despite his absence, Ross maintained Alaska residency and received a permanent fund dividend each year. In 1998 the Alaska Legislature amended the dividend qualifications to provide that anyone who was allowably absent for ten consecutive years would no longer be eligible for dividends. This ten-year rule, however, does not apply to members of the United States Congress, their staffs, or the families of either. In 2009 Ross and his children applied for dividends but were denied because Ross had then been absent for ten consecutive years from the enactment of the ten-year rule. They appealed the denial, but the denial was upheld at an informal agency appeal, a formal agency appeal, and by the superior court. Ross appealed to the Supreme Court, arguing that the ten-year rule violates his equal protection and substantive due process rights. Because the ten-year rule and congressional exception are fairly and substantially related to the legitimate state interests of limiting dividends to permanent Alaska residents and preventing fraud, and because the ten-year rule is rationally related to the legitimate state purpose of reducing administrative burdens, the Supreme Court affirmed the superior court as to these claims. View "Ross v. Dept. of Revenue" on Justia Law

The City of Gadsden appealed an order of injunctive relief in favor of John Boman, a retired Gadsden police officer. Boman and 18 other active and retired Gadsden police officers sued Gadsden alleging, among other things, that they had "been deprived of Social Security and Medicare protection which other police officers have been provided" and that, after 20 years of service, they were being required to pay a higher pension charge or percentage of base pay than their counterparts who were hired after April 1, 1986. Boman filed a "motion for immediate relief for medical care." He alleged that when he was hired, Gadsden "provided police and firemen a 20 year retirement program whereby police and firemen would receive 50% retirement benefits after 20 years of service and lifetime medical care." He averred that Gadsden had "breached its contract with [him] to provide continuing medical insurance," and he requested "immediate relief by ordering [Gadsden] to pay for [his] medical care or in the alternative ordering [Gadsden] to pay for Medicare coverage for ... Boman so he will have continuing medical insurance as agreed by the Board filed a motion to dismiss the action as to it and the plan. As to it, the Board alleged that it was an agency of the State and, therefore, was entitled to absolute immunity from suit. Also, according to the Board, the plan is not a legal entity subject to suit, but "merely a program administered by the Board to provide insurance." It also averred that, "[e]ven if [the plan] were an entity subject to suit, it would be immune for the same reasons [the] Board is immune." Boman's response to the Board's motion failed to acknowledge or mention the immunity question. The trial court, without conducting an evidentiary hearing, entered an "order granting motion for emergency relief." It ultimately dismissed the claims against the Board and the plan. Gadsden appealed. Upon review, the Supreme Court reversed based on the failure to join the officials of the Board, in their official capacities, as necessary parties. On remand, the trial court was directed to entertain an amendment to the complaint adding claims against those officials of the Board who are charged with administering the plan, in their official capacities. View "City of Gadsden, Alabama v. Boman et al. " on Justia Law

A man filed an application for both occupational and nonoccupational disability benefits from the Public Employees Retirement System, claiming disability from both physical and mental conditions. An administrative law judge (ALJ) denied his claim, finding that he failed to establish by a preponderance of the evidence that he had a physical or mental disability that presumably permanently prevented him from satisfactorily performing his job. The man appealed and the superior court affirmed the ALJ's determination. On appeal to the Supreme Court, the man challenged the ALJ's determination regarding his mental condition. Because the ALJ's written findings were sufficiently detailed to support the ALJ's conclusions, and because substantial evidence supported the ALJ's conclusion that the man’s mental condition did not amount to an occupational or nonoccupational disability, the Supreme Court affirmed the superior court’s decision to uphold the ALJ's order.View "McKitrick v. Alaska Pub. Employees Retirement Sys." on Justia Law

In 2011, the Pension and Health Care Benefits Act (Chapter 78) was enacted into law, a law that applied to all public employees, including Supreme Court justices and Superior Court judges then in service. Article VI, Section 6, Paragraph 6 of the New Jersey Constitution provides that justices and judges "shall receive for their services such salaries as may be provided by law, which shall not be diminished during the term of their appointment" (the No-Diminution Clause). The issue before the Supreme Court was whether Chapter 78 violated the New Jersey Constitution by diminishing the salaries of justices and judges during the terms of their appointments. Upon review, the Court concluded that it did. "Whatever good motives the Legislature might have, the Framers' message is simple and clear. Diminishing judicial salaries during a jurist's term of appointment is forbidden by the Constitution."View "DePascale v. New Jersey" on Justia Law

The North Dakota Department of Human Services ("the Department") appealed a district court judgment reversing the Department's order determining Edward Ennis was ineligible for continued Supplemental Nutrition Assistance Program ("SNAP") benefits. Ennis cross-appealed, challenging the district court's denial of his motion for costs. Ennis, self-employed, purchased a truck for $5,238 for use in his business. He paid for the truck in full and thus did not make ongoing payments. In March 2011, the County conducted a periodic recertification review to determine Ennis's continued eligibility for SNAP benefits. The County calculated his anticipated 2011 self-employment income based upon his actual 2010 self-employment income, without deducting the $5,238 expense for the truck. Based on this calculation, the County determined Ennis's anticipated 2011 income exceeded the income limit for SNAP benefits and issued a denial of benefits. Ennis appealed to the Department and requested a hearing. An administrative law judge ("ALJ") issued recommended findings of fact, conclusions of law and order determining that the purchase price of the truck should have been deducted from Ennis's anticipated 2011 self-employment income and recommending that the County's denial of further benefits be reversed. The executive director of the Department disagreed with the ALJ's recommendation and issued amended findings, conclusions and final order affirming the County's determination that Ennis was not entitled to further SNAP benefits. Ennis appealed to the district court, which reversed the Department's final order and reinstated the recommended findings of the ALJ. Upon review, the Supreme Court reversed the judgment and reinstated the Department's final order denying further benefits. View "Ennis v. N.D. Dep't of Human Services" on Justia Law

Wilfred Dahly appealed a district court judgment which affirmed a final order of the North Dakota Department of Human Services ("Department") which determined he was ineligible for Medicaid benefits. Upon review, the Supreme Court reversed and remanded, concluding the Department erred when it concluded the proceeds of the sale of Wilfred Dahly's home were an available asset which exceeded the asset limit for Medicaid eligibility.View "Dahly v. Anderson" on Justia Law

Appellant was a personal care attendant for a Medicaid beneficiary. Appellant was later charged with Medicaid fraud for submitting a false claim for his services. After a bench trial Appellant was convicted under Kan. Stat. Ann. 21-3846(a)(1) for defrauding the Medicaid program. The court of appeals reversed Appellant's conviction, holding that the complaint charged that Appellant submitted statements for services he did not provide while the evidence at trial established that Appellant actually did provide the services for which he submitted statements. The Supreme Court reversed the court of appeals and affirmed the district court, holding that sufficient evidence supported Appellant's conviction for Medicaid fraud.View "State v. McWilliams" on Justia Law

This appeal arose from a claim filed by the Idaho Department of Health and Welfare in the probate proceeding of George D. Perry, the deceased spouse of Medicaid recipient Martha J. Perry. The Department sought to recover funds under I.C. 56-218 from the sale of the couple’s home (their only significant asset) to recoup Medicaid benefits paid to Martha during her lifetime. The magistrate court disallowed the Department’s claim for recovery, finding that Martha had no interest in the real property because George, acting for Martha under a power of attorney, conveyed the property to himself before his death. That decision was upheld on appeal to the district court. The Department appealed to the Supreme Court. Upon review, the Court found that the district court erred in finding that federal law preempted the Department's ability to recover from George's estate what was once Martha's community property during the marriage. The Court reversed the district court and remanded the case for further proceedings.View "Id. Dept. of Health & Welfare v. McCormick" on Justia Law

Arnaz Crawford was fired from his job in January 2009. Crawford subsequently applied for Social Security disability benefits (SSDI benefits) due to a mental condition, but the social security administration (Administration) denied the claim. Meanwhile, Crawford applied for state unemployment benefits. The division of employment security (Division) awarded unemployment benefits to Crawford until March 20, 2010. On March 2, 2010, the Administration determined Crawford had been disabled and eligible for SSDI benefits since January 29, 2009. The Division subsequently determined (1) Crawford was unable to work from December 20, 2009 to March 20, 2010 and, therefore, was ineligible for unemployment compensation benefits; and (2) Crawford had received $3,080 in benefits that he was ineligible to receive. The labor and industrial relations commission (Commission) affirmed the determination that Crawford was ineligible for unemployment compensation benefits. The Supreme Court (1) reversed the Commission's decisions to the extent they authorized the Division to collect the overpayment from Crawford; but (2) otherwise affirmed the Commission's decision.View "Crawford v. Div. of Employment Sec." on Justia Law