Justia Public Benefits Opinion Summaries

Defendant was convicted by a jury of defrauding Medicaid and Medicare of $1.4 million. On appeal, defendant argued that the evidence was insufficient; prejudicial evidence was admitted; the jury instructions were flawed; her sentencing level was erroneously increased for obstruction of justice; and the district court erred by denying her request for post-trial contact with a juror. The court affirmed the judgment because there was sufficient evidence to support the conviction and there was no reversible error. View "United States v. Delgado" on Justia Law

Organizations challenged a rule issued by the Secretary of Veterans Affairs (amending 38 C.F.R 3.304(f)) with respect to claims for service-connected disability benefits for post-traumatic stress disorder. The new rule: allows a veteran to establish PTSD without supporting evidence; applies the lower evidentiary standard only if a VA psychologist or psychiatrist, or one contracted with the VA, confirms the claimed-stressor supports the diagnosis; and defines the veteran’s "fear of hostile military or terrorist activity" as involving a response characterized by "a psychological or psycho-physiological state of fear, helplessness, or horror." The Federal Circuit upheld the rule as not violating the statutory requirement that the Secretary consider all medical evidence and give the benefit of the doubt to the claimant when there is an approximate balance of evidence. There is a rational basis for the distinction between private practitioners and VA associated practitioners. View "Nat'l Org. of Veterans' Advocates, Inc. v. Sec'y Veterans Affairs." on Justia Law

Law Firm filed a verified petition for a writ of mandamus to compel Housing Authority to provide copies of all records that documented any and all instances of lead poisoning in the last fifteen years in any dwelling owned or operated by Housing Authority. The court of appeals (1) granted Law Firm's motion for summary judgment regarding the request for lead-poisoning documents and ordered Housing Authority to produce the documents, and (2) granted $7,537 in attorney fees to Law Firm. The Supreme Court reversed in part, holding (1) to the extent that Law Firm's request properly sought the lead-poisoning records, the court of appeals did not err in granting the writ of mandamus to compel Housing Authority to provide access to them; (2) the personal identifying information in Housing Authority's lead-poisoning documents was not obtainable under the Public Records Act, but the remainder of the completed forms was subject to disclosure; and (3) the court of appeals erred in awarding attorney fees to Law Firm. Remanded. View "State ex rel. O'Shea & Assocs. Co., L.P.A. v. Cuyahoga Metro. Hous. Auth." on Justia Law

In 2008, Chrysler offered a buyout program to employees in Kokomo, Indiana. Those employees then applied for unemployment benefits under Indiana's Unemployment Compensation Act. The Indiana Department of Workforce Development denied the claims. The Review Board of the Indiana Department of Workforce Development ultimately awarded benefits under a narrow provision of the Act. The court of appeals reversed, holding that the Board's application of the provision was erroneous and inconsistent with the statute. The Supreme Court granted transfer and vacated the court of appeals. The Court then affirmed the decision of the Board, holding that the Board properly applied the law to its findings of fact, and the Board's conclusion that the employees were eligible for benefits was reasonable in light of the evidence before it. View "Chrysler Group, LLC v. Review Bd. of the Dep't of Workforce Dev." on Justia Law

The owner of supermarkets involved his family in a scheme to provide cash for food stamps, beyond what is permitted by Puerto Rico law. A conservative estimate put receipts from the fraud above $4 million, which was intermingled with more than $20 million in food stamp proceeds. Family members testified and he was convicted of conspiracy to commit food stamp fraud, 7 U.S.C. 2024(b) and 18 U.S.C. 371, and for knowingly conducting and attempting to conduct financial transactions affecting interstate commerce involving the proceeds of unlawful activity, 18 U.S.C. 1956(a)(1)(A)(i) and 1956(a)(1)(B)(i), and 2, sentenced to 108 months in prison, and ordered to forfeit $20 million. The First Circuit affirmed. The district court properly applied a sentencing enhancement for the owner's leadership participation in the scheme. Even legitimate funds are subject to forfeiture when they become involved in a scheme to conceal illegal funds. The court properly weighed the harm caused by the crime. View "United States v. Aguasvivas-Castillo" on Justia Law

In 2003, the New Hampshire Department of Health and Human Services and a certified class of Medicaid-eligible children reached a settlement agreement and proposed a consent decree that outlined the Department's obligations to provide dental services to Medicaid-enrolled children in accordance with federal law. The district court approved the Decree in 2004. Between 2007 and 2010, the district court denied four motions alleging that the Department was not in compliance. The First Circuit affirmed, upholding the district court's requirement that the Class to file a motion for contempt to enforce the Decree; denial of a 2010 motion for contempt; denial of a request for an evidentiary hearing in 2010; and holding the Class to a clear and convincing burden of proof on its 2010 motion to modify or extend the Decree. View "Hawkins v. Dep't of Health & Human Servs. for the State of NH" on Justia Law

Respondent-Appellant Pneumotech, Inc. appealed the Industrial Commission's determination that its former employee, Petitioner-Appellee Angela Hopkins, was eligible for unemployment benefits. Pneumotech hired Petitioner as a bookkeeper and receptionist on July 3, 1995. She worked at Pneumotech until June 22, 2010, when her supervisor fired her. The same month, Petitioner filed a claim for unemployment benefits with the Idaho Department of Labor. At the hearing, Pneumotech presented testimony that Petitioner was discharged because: (1) for two years she had been habitually late for work; (2) she took time off without supervisor permission; (3) she took sick time off but went to the water park instead; (4) she spent time at work playing video games and talking on her cell phone; and (5) she failed to help train a new employee when asked. Petitioner denied all of these accusations, including that her supervisor had repeatedly warned her that her conduct was unacceptable. In fact, the supervisor testified that Petitioner never received a written warning or suspension, and in January 2009, she received a $2-per-hour raise. Upon review, the Supreme Court found that the Commission did not abuse its discretion or violate Pneumotech's right to procedural due process in denying the company's request for a new hearing. Furthermore, substantial and competent evidence supported the Commission's decision to uphold Petitioner's award of unemployment benefits. Accordingly, the Court affirmed. View "Hopkins v. Pneumotech, Inc." on Justia Law

This case involved Commonwealth Care, a state-initiated program that provided structured premium assistance for low-income Massachusetts residents. In 2009, the Legislature made certain changes to the eligibility requirements of Commonwealth Care, enacted in a two-part supplemental appropriation for fiscal year 2010. Section 31(a) of the appropriation excluded all aliens who were federally ineligible under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), 8 U.S.C. 1601-1646, from participation in Commonwealth Care. Plaintiffs were individuals who either have been terminated from Commonwealth Care or have been denied eligibility solely as a result of their alienage. The court held that section 31(a) could not pass strict scrutiny and that the discrimination against legal immigrants that its limiting language embodied violated their rights to equal protection under the Massachusetts Constitution. View "Finch & others v. Commonwealth Health Ins. Connector Auth. & others" on Justia Law

Plaintiff appealed the district court's order affirming the Commissioner's denial of her application for supplemental security income (SSI). The court found that substantial evidence supported the ALJ's conclusion that plaintiff was not disabled within the meaning of the Social Security Act, 42 U.S.C. 301 et seq. Accordingly, the court affirmed the district court's grant of judgment on the pleadings in favor of the Commissioner. View "Hancock v. Astrue" on Justia Law

Petitioner, a bookkeeper, part-time receptionist, and house-cleaner, developed reflexive sympathetic dystrophy after she fell. After reducing her hours, she stopped working in April 2008. Her application for disability benefits and SSI was denied in June 2008. In June 2009, she had a hearing before an ALJ, who denied her applications, finding that she was not disabled because she had the residual functional capacity to perform sedentary work with certain limitations and that jobs meeting those criteria were available. Eight months later, the Appeals Council denied review. The district court held that the ALJ's RFC determination was not supported by substantial evidence. The Third Circuit reversed, holding that the ALJ adequately explained the decision and properly relied on a 2008 report by the state agency medical consultant. View "Chandler v. Comm'r of Soc. Sec." on Justia Law