Justia Public Benefits Opinion Summaries

Claimant Katherine St. Martin appealed the Employment Security Board's determination that she voluntarily left her job without good cause, disqualifying her from receiving unemployment benefits. She argued on appeal that her decision to quit her job was with good cause because she reasonably believed she would not receive a paycheck for her work. Claimant worked for almost two years for her employer as an assistant financial supervisor, which required her to prepare payroll information weekly. At some point, her employer began to have financial difficulties, and the payroll submission day was moved back to later in the week. The president of Claimant’s employer told claimant not to submit payroll because there were inadequate funds to cover the checks. The president then attempted to borrow money to meet the payroll, which ultimately proved "fruitless." The chief of operations persuaded the president to close the business and pay the employees. Claimant submitted the payroll after being given permission to do so by the president. She then printed the checks, and distributed them to the employees. After the president told claimant that the checks would bounce due to lack of funds, Claimant quit. Upon review, the Supreme Court held that Claimant should not have been penalized for leaving her job when she was told not to expect a paycheck. The president's statement amounted to "good cause." View "St. Martin v. Dept. of Labor" on Justia Law

Plaintiffs sued the Government, seeking to disclaim their legal entitlement to Medicare Part A benefits for hospitalization costs. Plaintiffs wanted to disclaim their legal entitlement to such benefits because their private insurers limited coverage for patients who were entitled to Medicare Part A benefits. Plaintiffs preferred to receive coverage from their private insurers rather than from the Government. The district court granted summary judgment for the Government because there was no statutory authority for those who were over 65 or older and receiving Social Security benefits to disclaim their legal entitlement to Medicare Part A benefits. The court understood plaintiffs' frustration with their insurance coverage. But based on the law, the court affirmed the judgment of the district court. View "Hall, et al. v. Sebelius, et al." on Justia Law

Mrs. T. was the mother of C.T., a fifteen-year-old boy with severe disabilities. At issue in this case was C.T.'s eligibility for the Department of Health and Human Services' home and community-based waiver program. C.T. was approved for the waiver program but was not receiving services under the waiver when the Department instituted a new regulation that closed the program to children but grandfathered children who were already receiving services. Mrs. T. subsequently filed a grievance with the Department seeking to have C.T. declared waiver-eligible. The Commissioner of the Department accepted the recommendation of an administrative hearing officer that denied the grievance. The superior court affirmed. Mrs. T. appealed, contending that the Department was equitably estopped from denying services because she reasonably relied to her detriment on misinformation she received that C.T. was eligible. The Supreme Court affirmed, holding that because Mrs. T. did not meet her burden to prove that her reliance on the misinformation given to her by the Department caused any detriment to C.T., the hearing officer did not err in finding that the Department was not equitably estopped from declaring C.T. ineligible for a waiver. View "Mrs. T. v. Dep't of Health & Human Servs." on Justia Law

In 2009, plaintiff applied for an IT specialist position with the Miami VA Healthcare System. He did not get the job and, after exhausting rights before the Department of Labor, filed an appeal, asserting that the VA violated his rights relating to veteran's preference. The AJ concluded that the Merit Systems Protection Board had no authority to review the merits of the VA’s non-selection of plaintiff. The Board agreed. The Federal Circuit vacated. There is no way to determine whether the Veterans' Preference Act (58 Stat. 390) has been violated without examining the grounds for non-selection. The Board has jurisdiction to determine whether the VA properly afforded plaintiff the right to compete for the job and properly determined, in accordance with 5 C.F.R. § 302.302(d), that he was not qualified for the position View "Lazaro v. Dep't of Veterans Affairs" on Justia Law

ESBC, billing agent for the Fire Department, determined that each of the individual defendants owned a vehicle involved in a collision to which the Fire Department responded and each had insurance coverage, and billed response costs incurred for each collision. The defendants refused to pay and ESBC sought a declaration that defendants were liable under the Comprehensive Environmental Response, Compensation, and Liability Act, 42 U.S.C. 9601. Under CERCLA, the owner of a “facility” from which hazardous substances have been released is responsible for response costs that result from the release. Insurer-defendants counterclaimed for injunctive relief from ESBC’s billing practices and alleging violation of the Fair Debt Collection Practices Act, 15 U.S.C. 1692, unjust enrichment, unlawful fee collection, fraud, constructive fraud, and insurance fraud. The district court granted defendants judgment on the pleadings and dismissed counterclaims without prejudice. The Seventh Circuit affirmed. Motor vehicles for personal use fall under the "consumer product in consumer use” exception to CERCLA’s definition of facilityView "Emergency Serv. Billing Corp., Inc. v. Allstate Ins. Co." on Justia Law

After a 1999 auto accident, plaintiff had severe back pains and was diagnosed with a Chiari malformation, a protrusion of brain tissue into the spinal canal. After three operations on her brain and spine, her vision and speech problems lessened, but she developed hydrocephalus, a buildup of cerebrospinal fluid in the brain that required installation of a shunt in her brain. She has not worked since the auto accident and was last insured for social security disability benefits in June 2005 (when she was 34 years old), so only if she was disabled from full-time work by that date is she eligible for benefits. An administrative law judge found her capable of sedentary work. The Seventh Circuit reversed, finding that the ALJ failed to bridge the gap between medical testimony and plaintiff's testimony and his conclusion. View "Bjornson v. Astrue" on Justia Law

Plaintiff, pro se and incarcerated, appealed the district court's order denying his post-judgment motion for an order directing the Social Security Administration (SSA) to re-tender a check for retroactive supplemental social security benefits that he was owed. The court held that the No Social Security Benefits for Prisoners Act, Pub. L. No. 111-114, 123 Stat. 3029, barred the SSA from making any payment to an incarcerated individual covered by the Act, regardless of when the underlying obligation to pay the individual arose. Accordingly, the court affirmed the district court's denial of plaintiff's motion. View "Fowlkes v. Thomas, et al." on Justia Law

Appellants are the parents of G.J., a child with autism and brain injuries. At issue was whether the ALJ and the district court properly evaluated appellants' claims that the MCSD did not comply with certain provisions of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., with respect to services it was to provide to G.J. The court held that the district court did not err in setting forth reasonable conditions for G.J.'s reevaluation and in determining that appellants were not entitled to either a private or publicly funded independent educational evaluation. The court also held that there was no basis for making a determination that any procedural failures with regard to the August 2008 and 2009 IEP meetings impacted the education received by G.J. to any substantive degree. Accordingly, the judgment was affirmed. View "G. J., et al. v. Muscogee Co. Sch. Dist." on Justia Law

Alohacare, a health maintenance organization (HMO), submitted a proposal to the Department of Human Services to bid for a Quest Expanded Access contract to provide healthcare services for participants in the state's Medicaid program. The Department of Human Services awarded Quest contracts to United HealthCare Insurance (United) and WellCare Health Insurance (Ohana) but not to Alohacare. Alohacare petitioned the Insurance Commissioner of the Department of Commerce and Consumer Affairs for declaratory relief that the Quest contracts required the accident and health insurers to carry an HMO license. The Commissioner concluded that the license was not required to offer the Quest managed care product because the services required under the contracts were not services that could be provided only by an HMO. The circuit court affirmed. The Supreme Court affirmed, holding (1) AlohaCare had standing to appeal the Commissioner's decision; (2) both accident and health insurers and HMOs were authorized to offer the model of care required by the Quest contracts; and (3) this holding did not nullify the Health Maintenance Organization Act. View "Alohacare v. Ito" on Justia Law

Defendant filed a due process hearing complaint with California's Office of Administrative Hearings (OAH), alleging that he was being denied the free appropriate public education (FAPE) that he was entitled to under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court certified the following question to the California Supreme Court: Does California Education Code 56041 - which provided generally that for qualifying children ages eighteen to twenty-two, the school district where the child's parent resides is responsible for providing special education services - apply to children who are incarcerated in county jails? The case was withdrawn from submission and further proceedings were stayed pending final action by the Supreme Court of California. View "Los Angeles Unified Sch. Dist. v. Garcia" on Justia Law