Justia Public Benefits Opinion Summaries

Plaintiff-Appellant Jeffrey McFerran appealed a district court judgment that affirmed the Commissioner of Social Security’s denial of his application for disability benefits. Plaintiff sought benefits based on degenerative disc disease of the lumbar and cervical spine and associated pain; coronary artery disease; hypertension; obesity; post surgery hernia; knee and shoulder limitations; depression; and anxiety. He had worked for the postal service following 40 years with the Air Force. The Veterans Administration determined Plaintiff was "entitled to receive service connected compensation at the 100 percent rate." An administrative law judge (ALJ) denied benefits at the last step of the five-step sequential process for determining disability. Finding that the Commissioner failed to follow the correct legal standards in denying benefits, the Tenth Circuit reversed Plaintiff’s case and remanded it for further proceedings.

Plaintiff Jerry Elliott sought workers' compensation benefits from his employer, International Paper Company, Inc. (IP). He petitioned the Supreme Court for a writ of mandamus to quash a Court of Civil Appeals' writ of mandamus directed to the Conecuh Circuit Court. Plaintiff lived in Conecuh County for over 15 years and for 21 years worked as a machine operator at the plywood-manufacturing plant owned by IP located in Butler County. In 2007, he allegedly sustained an injury to his shoulder while at work. He filed an action at the Conecuh Circuit Court seeking workers' compensation benefits. IP filed motions to dismiss Plaintiff's action or, in the alternative, to transfer the case to Butler County. After a hearing, the trial court denied the motions to dismiss or to transfer. IP then filed a petition for the writ of mandamus at the Court of Civil Appeals to review the trial court's denial of its motion. The Court of Appeals granted the writ directing the Conecuh Court to transfer the case to Butler County. Upon review, the Supreme Court concluded the appellate court's decision was in error, and quashed the writ that was issued transferring venue to Butler County.

In 1996 the State sued Defendant Troy Wolff, seeking to establish his paternity and obtain a child support order after the mother and child began receiving public assistance. The court also established a child support obligation for Defendant. The mother was given custody of the child. In 1999 Defendant and the mother stipulated to a reduction of Defendant's child support obligation, and an amended judgment was entered incorporating the stipulation. The State was a party to the action and signed the 1999 stipulation. In January 2009, Defendant and the mother entered into another stipulation pertaining to custody and visitation, and they agreed to modify the child support obligation. The parties agreed that Defendant would no longer have a support obligation to the mother, and that Defendant would not seek support from the mother. The court entered a second amended judgment incorporating the new stipulation. In October 2009, the State moved to vacate the second amended judgment, arguing that it was a party to the action and did not agree to the new stipulation. Defendant argued on appeal that the judicial referee did not have jurisdiction to issue the order to vacate the second amended judgment. Upon review, the Supreme Court concluded that the State was a real party in interest and had standing, the second amended judgment contains unenforceable provisions, and the court did not err in vacating the second amended judgment.

In 1971 the veteran unsuccessfully sought benefits. In 1979, he sought to reopen and provided a psychiatric evaluation. The veteran took steps to appeal the regional office's refusal to reopen. The regional office requested form I-9 to "reactivate" the appeal. He responded that he had already sent the form. The VA responded in 1980 that no further action would be taken unless he submitted the form within 30 days. The veteran did not respond. In 1994, he again sought to reopen. The regional office granted him service connection for bipolar disorder with an effective date of 1994. He contended that the effective date should be 1979. In 2005 the Board rejected his "pending claim" argument because he had not filed Form 1-9 within one year of the 1979 decision. The veterans court agreed. The Federal Circuit reversed. An appeal should set out specific allegations of error of fact or law, such allegations related to specific items in the statement of the case (38 U.S.C. 7105(d)(3) ); the statute must be construed liberally. Since there was a single issue identified in the statement of the case, the 1980 letters were sufficient to identify the issue on appeal and satisfy the statute.

King County sought ways to provide legal defense services to indigent criminal defendants. The County settled on a system of using nonprofit corporations to provide services funded through and monitored by the County's Office of the Public Defender (OPD). Over time, the County took steps to improve and make these nonprofit organizations more accountable to the County. In so doing, it asserted more control over the groups that provided defender services. Respondents are employees of the defender organizations who sued the County for state employee benefits. They argued the County's funding and control over their "independent" organizations essentially made them state employees for the purposes of participating in the Public Employees Retirement System (PERS). Applying the pertinent statues and common law principles, the Supreme Court agreed that employees of the defender organizations are "employees" under state law, and, as such, are entitled to be enrolled in the PERS.

The Medicare program pays teaching hospitals to cover "direct" and "indirect costs of medical education," 42 U.S.C. 1395ww(d)(5)(B), (h). Direct costs include expenses such as residents' salaries. Indirect costs are incurred due to "general inefficiencies" and "extra demands placed on other staff." Congress created a formula for calculating indirect expenses based on full-time equivalency interns; an HHS regulation referred to time residents spend in the "portion of the hospital subject to the prospective payment system or in the outpatient department of the hospital." In reimbursing plaintiff, HHS excluded from the FTE count time residents spent on pure research, unrelated to treatment of a patient. While appeal of a decision favoring the hospital was pending, Congress enacted the Patient Protection and Affordable Care Act, 124 Stat. 119, 660–61. For the years at issue, HHS must include in FTE: "all the time spent by an intern or resident in an approved medical residency training program in non-patient care activities, such as didactic conferences and seminars, as such time and activities are defined by the Secretary." HHS promulgated a regulation specifying that eligible non-patient care activities do not include time residents spend conducting pure research. The Sixth Circuit upheld the regulation as within the Secretary's authority and applicable to the years at issue.

Plaintiff-Appellant Patrick Dorman appealed a district court's denial of his request for an Equal Access to Justice (EAJA) fee. Plaintiff filed his application for social security disability benefits in 2004 alleging that he became disabled on December 30, 2003, due to breathing problems and depression. The agency denied his applications initially and on reconsideration. Plaintiff obtained a hearing before an administrative law judge (ALJ) who determined that he could return to his past relevant work and, therefore, upheld the denial of his application. Plaintiff then appealed administratively to the Appeals Council, which denied review of the ALJ’s decision. Plaintiff thereafter unsuccessfully appealed the Council's decision to the district court. Plaintiff then appealed to the Tenth Circuit court, raising essentially the same issues he had presented in the district court but this time focusing his argument on the ALJ’s failure to properly evaluate his mental impairments. The Tenth Circuit found merit to Plaintiff's argument and overturned the lower courts' decisions. Plaintiff's counsel thereafter petitioned the district court for an award of EAJA fees. Upon review, the Tenth Circuit concluded the district court abused its discretion in denying Plaintiff's EAJA fee motion. Consequently, the Court reversed the district court’s denial of his EAJA motion for fees and costs, and remanded the case with instructions to grant the motion and to award a reasonable fee and appropriate costs to Plaintiff.

Employee-Petitioner Melenia Trotter was awarded workers' compensation benefits for a back injury by the South Carolina Workers' Compensation Commission ("Commission").  Petitioner worked at "the turb and trim station," which consisted of using an "air driver" (a screwdriver with a blade) to trim down tubes to the same length, and then "turbulating" the tubes by putting a spring into each tube. According to Petitioner, she began having spasms and some lower back pain that extended down her legs in December 2004, which she mentioned to her Team Leader and Trane's Safety Coordinator.  Petitioner continued to work with increasing discomfort in December 2004 and January 2005. An MRI revealed Petitioner had a herniated disc at L5-S1 with marked compression of the right S1 nerve root.  Following a doctor's recommendation, Petitioner underwent surgery in early 2005. In May 2005, Petitioner filed a claim alleging a job-related injury to her back. Trane denied the claim, maintaining it did not receive notice of the injury until after her surgery and that there was insufficient proof of a work-related injury. An Appellate Panel of the Commission unanimously upheld the commissioner's order finding Petitioner's injury was work related and granted her benefits.  The circuit court affirmed.  Trane appealed, and the appellate court reversed. Upon review, the Supreme Court concluded the Court of Appeals erred in finding the Commission abused its discretion in denying Trane's motions for a continuance or to keep the record open for depositions to be taken.  Consequently, the Court reversed the opinion of the Court of Appeals and reinstated the order of the Commission. 

In this case, the court construed Labor Code section 4659(c), which provided for the annual indexing of two categories of workers' compensation benefits, total permanent disability and life pension payments, to yearly increases in the state's average weekly wage (SAWW), so that lifetime disability payments made to the most seriously injured workers would keep pace with inflation. The indexing procedure was sometimes referred to as an "escalator," or one providing for "cost of living adjustments" (COLA's). At issue was whether the operative language of section 4659(c) required the annual COLA's for total permanent disability and life pension payments to be calculated (1) prospectively from the January 1 following the year in which the worker became "entitled to receive a life pension or total disability indemnity," (when the payments actually commenced); (2) retroactively to January 1 following the year in which the worker sustained the industrial injury; or (3) retroactively to January 2004, in every case involving a qualifying industrial injury, regardless of the date of injury or the date the first benefit payment became due. Applying fundamental rules of statutory construction, the court held that the Legislature intended that COLA's be calculated and applied prospectively commencing on the January 1 following the date on which the injured worker first became entitled to receive, and actually began receiving, such benefits payments, i.e., the permanent and stationary date in the case of total permanent disability benefits, and the date on which partial permanent disability benefits became exhausted in the case of life pension payments.

Respondent Alan Cote appealed a family court's garnishment order that directed the Social Security Administration to withhold his Social Security benefits to offset alimony arrearages. On appeal, Respondent contended that the garnishment order violated a provision of the Federal Consumer Credit Protection Act which imposes a cap on the percentage of aggregate disposable earnings that any court, state or federal, may garnish. While the trial court garnished only Respondent's Social Security disability benefits and not his veterans' disability benefits, the court did include the latter in its calculation of aggregate disposable earnings.  This broad calculation of disposable earning increased the percentage of Respondent's Social Security payments subject to garnishment.  Respondent contended that as defined and excluded from such a calculation by federal law, his particular veterans' disability benefits were not to be counted as earnings because they were not paid for a service related disability and are not received in lieu of retirement payments to which he would otherwise be entitled as earnings.  Upon review of the lower court's record and calculations, the Supreme Court agreed, reversed the lower court's order and remanded the case for recalculation of the garnishment.