Justia Public Benefits Opinion Summaries

The defendant, who had been receiving disability insurance benefits due to a medical diagnosis, operated a jewelry business while collecting these benefits. The Social Security Administration (SSA) began investigating after suspecting that the defendant was earning income that could affect his eligibility. The SSA asked the defendant whether he had worked or received income since his diagnosis, to which he responded negatively. However, evidence showed that he had significant gross income from jewelry sales, and the SSA determined that his countable income likely exceeded regulatory caps, making him ineligible for benefits. The defendant was subsequently charged with taking government property and making false statements.The United States District Court for the District of New Mexico presided over the trial. The government presented evidence of substantial gross income and efforts by the defendant to conceal earnings. The defendant did not provide information about business expenses that could have reduced his countable income. The jury convicted him on multiple counts related to theft of government property and false statements. At sentencing, the district court calculated the loss amount, including benefits paid to the defendant’s children and payments made outside the charged period, resulting in a 15-month prison sentence.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the evidence was sufficient for a reasonable jury to find that the defendant’s countable income exceeded the regulatory caps, even without detailed expense information, given the high gross income and lack of contrary evidence. The court also found no reversible error in the jury instructions, as the defendant failed to timely challenge the district court’s reasoning. Regarding sentencing, the court held that it was proper to include reasonably foreseeable payments to the defendant’s children and payments outside the charged period in the loss calculation. Any error in including Medicare premiums was deemed harmless. The convictions and sentence were affirmed. View "United States v. Sandoval" on Justia Law

A tenant entered into a lease for an apartment in Minneapolis that was subsidized under the Section 8 project-based voucher program, with the local public housing authority paying most or all of the rent directly to the landlord. After the tenant fell behind on utility payments, her electricity was disconnected, and she and her boyfriend broke into the building’s utility closet to restore power, inadvertently affecting other units. The landlord learned of this breach but continued to accept three months of rental payments from the public housing authority on the tenant’s behalf. Later, the landlord filed an eviction action based on the tenant’s breach of the lease.The Hennepin County District Court dismissed the tenant’s counterclaim regarding the utility shutoff and, following the Minnesota Court of Appeals’ decision in Westminster Corp. v. Anderson, held that the common law doctrine of waiver by acceptance of rent did not apply to rental payments made by a public housing agency. The district court found the tenant had materially breached the lease and did not address her retaliation defense. The Minnesota Court of Appeals affirmed the district court’s rulings on the waiver and breach issues but remanded for consideration of the retaliation defense.The Minnesota Supreme Court reviewed only the waiver issue. It overruled Westminster, holding that the common law rule—whereby a landlord who accepts rent with knowledge of a tenant’s breach waives the right to evict for that breach—applies equally to private and publicly subsidized tenancies. The court clarified that whether a landlord has accepted rent for purposes of this doctrine is a factual question, to be determined by the totality of the circumstances, including the landlord’s conduct after payment. The Supreme Court reversed the court of appeals and remanded for further proceedings. View "Hook & Ladder Apartments, L.P. v. Nalewaja" on Justia Law

The defendant was cited for a third offense of driving under the influence (DUI) and for driving with a suspended license, both misdemeanors, in November 2021. He was initially convicted in Justice Court and then sought a trial de novo in the District Court. At trial, a jury found him guilty of both offenses. During sentencing, the defendant’s counsel informed the court that the defendant was on a limited income, receiving disability and social security, and requested that the court consider his financial situation when imposing fines and fees, including a request to waive the public defender fee.After the jury verdict in the Twenty-First Judicial District Court, the court sentenced the defendant to jail time, most of which was suspended, and imposed a $3,000 fine with statutory surcharges and a $250 public defender fee. The written judgment also included a $10 technology fee and $50 in prosecution costs, which were not mentioned in the oral pronouncement. The defendant appealed, arguing that the written judgment conflicted with the oral sentence and that the court failed to consider his ability to pay the fines and fees.The Supreme Court of the State of Montana reviewed the case. It held that when there is a conflict between the oral sentence and the written judgment, the oral sentence controls, and thus the $10 technology fee and $50 prosecution costs should not have been included. The court further held that the District Court erred by failing to inquire into the defendant’s ability to pay the public defender fee, the $3,000 fine, and the statutory surcharges, as required by Montana statutes. The Supreme Court reversed the sentence and remanded the case for a new sentencing hearing consistent with its opinion. View "State v. Post" on Justia Law

The case concerns the fatal shooting of Brett Ness in Billings, Montana, following a series of drug-related disputes. Alexander Garrett LaForge III, along with several others, was involved in confrontations with Ness over an alleged shortfall in a methamphetamine transaction. After escalating tensions and threats, LaForge and a group of associates returned to Ness’s trailer, where LaForge shot Ness in the head with a .45 caliber pistol. Ness died later that day. Multiple co-defendants received plea deals in exchange for their testimony against LaForge.The Thirteenth Judicial District Court, Yellowstone County, presided over LaForge’s trial. LaForge requested a substitution of counsel shortly before trial, citing communication issues and dissatisfaction with his attorney’s preparation. The District Court conducted an inquiry and denied the request, finding no substantial breakdown in communication. During trial, LaForge also requested a cautionary jury instruction regarding the credibility of co-defendants’ testimony, which the District Court declined, instead providing standard witness credibility instructions and a specific instruction regarding one co-defendant’s accountability. The jury convicted LaForge of deliberate homicide. At sentencing, the court ordered LaForge to pay $72,000 in restitution to the victim’s mother for lost business income, based on her testimony about canceled jobs following her son’s death.The Supreme Court of the State of Montana reviewed the case. It held that the District Court did not abuse its discretion in denying LaForge’s request for substitute counsel or in its jury instructions regarding co-defendant testimony. However, the Supreme Court found that the $72,000 restitution award was not supported by sufficient evidence and that the record was unclear as to whether the victim’s mother, as a business representative, qualified as a “victim” under the restitution statutes. The Supreme Court affirmed the conviction and other aspects of the judgment, reversed the restitution award, and remanded for a new hearing to determine the proper amount and recipient of restitution. View "State v. LaForge" on Justia Law

A group of plaintiffs filed suit against the Secretary of the Alabama Department of Workforce, alleging that the Department’s handling of their unemployment benefits applications during the COVID-19 pandemic was unlawful. The plaintiffs claimed that the Department’s policies and practices resulted in unreasonable delays and inadequate communication, violating both the Social Security Act and the Due Process Clause of the Fourteenth Amendment. They sought various forms of injunctive relief, including orders requiring prompt decisions on applications, timely payment of approved claims, and clearer communication with claimants.The Montgomery Circuit Court granted the Secretary’s motion to dismiss the case, without specifying the grounds for dismissal. The plaintiffs’ motion to alter or vacate the judgment was denied. On appeal, the Supreme Court of Alabama affirmed the dismissal, holding that the plaintiffs had not exhausted their administrative remedies and that the courts lacked the power to address the merits of their claims. The plaintiffs then sought review by the United States Supreme Court.The United States Supreme Court reversed the Alabama Supreme Court’s judgment, holding that the state’s administrative exhaustion requirement could not be used to bar federal due process claims under 42 U.S.C. § 1983 for alleged delays in processing unemployment benefits. On remand, the Supreme Court of Alabama considered supplemental briefing on whether the case had become moot, as the Secretary asserted that all plaintiffs had either been paid or received final denials. The plaintiffs disputed this and requested a remand for a factual determination. The Supreme Court of Alabama remanded the case to the Montgomery Circuit Court to determine whether the case is now moot, instructing the lower court to resolve the factual dispute regarding mootness. View "Johnson v. Reed" on Justia Law

Lydia Galvez applied for Social Security disability insurance benefits, claiming disability from 2008 to 2018 due to various medical conditions. Her initial claim was denied by an Administrative Law Judge (ALJ) in 2013, who found she could perform light work. After Galvez appealed, the United States District Court for the Eastern District of Washington remanded the case in 2017 for further evaluation of her fibromyalgia diagnosis. On remand, the same ALJ, whose appointment had since been ratified, again denied benefits in 2019, incorporating parts of his earlier decision. Subsequent proceedings led to the assignment of a new ALJ, who held additional hearings, considered new evidence, and ultimately found Galvez not disabled for the period in question, though he found her disabled as of January 1, 2019 due to a new injury.After the new ALJ’s decision, Galvez again appealed to the district court, arguing that the decision was tainted by reliance on findings from the prior, improperly appointed ALJ, thus violating the Appointments Clause. The district court agreed, holding that the new ALJ’s decision was not independent because it incorporated portions of the earlier, tainted decision, and remanded the case for a new hearing before a different ALJ.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that a new ALJ’s decision is not automatically tainted by an Appointments Clause violation simply because it incorporates or echoes portions of a prior, tainted decision. The key inquiry is whether the new ALJ provided an independent assessment. The Ninth Circuit found that the new ALJ conducted additional hearings, considered new evidence, and made independent findings, thus satisfying the requirement for a fresh, independent review. The Ninth Circuit vacated the district court’s order and remanded for consideration of the merits of Galvez’s claim. View "GALVEZ V. BISIGNANO" on Justia Law

Catherine Baker was employed by San Mateo County as a Social Worker III but went on medical leave in 2009 due to back pain. In 2015, she returned to work in a different position as a screener trainee, which involved different duties but was compensated at the same pay rate as her original position. Her last paycheck was issued in January 2016. In 2017, Baker applied for a service-connected disability retirement, and the San Mateo County Employees Retirement Association (SamCERA) determined that the effective date for her retirement benefits should be January 22, 2016, the day after her last receipt of “regular compensation.”After SamCERA’s Board approved her application and set the effective date, Baker sought administrative review, arguing that her compensation as a screener trainee did not qualify as “regular compensation” under Government Code section 31724 because she had not returned to her original job. An administrative law judge recommended denial of her request to change the effective date, and the Board adopted this recommendation. Baker then filed a petition for writ of administrative mandamus in the Superior Court of San Mateo County, which denied the petition and confirmed the January 22, 2016 effective date.On appeal, the California Court of Appeal, First Appellate District, Division One, reviewed whether “regular compensation” under section 31724 included Baker’s pay as a screener trainee. Exercising independent judgment on statutory interpretation, the court held that “regular compensation” refers to regular salary or full wages, regardless of whether the position is the employee’s original job. Because Baker’s screener trainee pay matched her original position’s rate, it qualified as “regular compensation.” The court affirmed the trial court’s judgment, upholding the effective date set by SamCERA. View "Baker v. San Mateo County Employees Retirement Assn." on Justia Law

A plaintiff who lost his job during the COVID-19 pandemic applied for and received regular unemployment benefits from the Washington State Employment Security Department (ESD). After exhausting those benefits, he applied for and received additional benefits under the federally funded Pandemic Emergency Unemployment Compensation (PEUC) program, created by the CARES Act. Following an audit, ESD redetermined his eligibility, reduced his weekly benefit, and assessed overpayments, sending him multiple, confusing notices with inconsistent information and deadlines. While the plaintiff appealed, ESD began offsetting his ongoing PEUC benefits to recover the alleged overpayments.An administrative law judge later found that ESD’s notices failed to provide adequate explanation or legal basis for the benefit reductions and overpayment assessments, and ordered ESD to issue a new redetermination. ESD reimbursed the plaintiff for the offset amounts, but its system continued to show a balance owed. The plaintiff, on behalf of himself and similarly situated individuals, filed a putative class action in the United States District Court for the Western District of Washington, alleging deprivation of property without due process under the Fourteenth Amendment and the Social Security Act. The district court held that while the plaintiff had a property interest in regular unemployment benefits, he did not have a constitutionally protected property interest in PEUC benefits, because state participation in the PEUC program was voluntary and could be terminated at any time.On interlocutory appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s ruling. The Ninth Circuit held that the CARES Act’s PEUC program, once a state opted in, created a constitutionally protected property interest in PEUC benefits for eligible individuals. The Act’s mandatory language and objective eligibility criteria significantly constrained state discretion, giving rise to legitimate claims of entitlement. The case was remanded for further proceedings. View "STERLING V. FEEK" on Justia Law

The plaintiff, a former machine operator with a high school education, stopped working after a workplace injury and subsequently experienced a range of medical issues, including spinal stenosis, degenerative joint disease, carpal tunnel syndrome, arthritis, depression, and anxiety. In November 2018, she applied for disability insurance benefits, claiming her disability began in March of that year. Her application was denied at multiple stages within the Social Security Administration (SSA), including after a hearing before an administrative law judge (ALJ). The SSA Appeals Council denied her request for review, prompting her to seek judicial review.The United States District Court for the Northern District of Mississippi reversed and remanded the ALJ’s decision, instructing the ALJ to specifically evaluate certain medical opinions, including that of Dr. William Booker, in accordance with relevant regulations. On remand, the ALJ held another hearing, considered extensive medical evidence and testimony, and again found that while the plaintiff had several severe impairments and could not perform her past work, she retained the residual functional capacity to perform light work with certain restrictions. The ALJ concluded that jobs existed in significant numbers in the national economy that she could perform, and thus she was not disabled. The Appeals Council adopted this as the final decision of the Commissioner. The district court, with the consent of both parties, affirmed the Commissioner’s decision, and the plaintiff appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit reviewed whether the Commissioner’s decision was supported by substantial evidence and whether proper legal standards were applied. The court held that the ALJ’s decision was supported by substantial evidence and that any alleged errors did not prejudice the plaintiff’s substantial rights. The court affirmed the judgment of the district court. View "Madkins v. Bisignano" on Justia Law

The plaintiff, a Nebraska resident, received Medicaid benefits administered by the Nebraska Department of Health and Human Services (NDHHS). In April 2024, she was sent a notice stating her Medicaid eligibility was ending due to income exceeding program standards. The notice informed her of her rights to request a conference or appeal and outlined the process for a fair hearing. She did not appeal the termination, and her coverage ended on May 1, 2024. Subsequently, she filed a federal lawsuit on behalf of herself and similarly situated individuals, alleging that the termination notices failed to meet due process requirements and seeking class certification, declaratory and injunctive relief, including reinstatement of benefits until proper notice was provided.The United States District Court for the District of Nebraska considered only her individual claims, as she did not challenge the court’s decision to exclude class claims on appeal. The district court denied her request for a temporary restraining order, finding she was unlikely to succeed because her claims sought retroactive relief barred by sovereign immunity and because the notices likely satisfied due process. The court then dismissed her complaint for lack of subject matter jurisdiction, concluding she had not alleged an ongoing violation of federal law and was not seeking prospective relief, as required to invoke the Ex parte Young exception to Eleventh Amendment immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s dismissal. The Eighth Circuit held that the plaintiff’s alleged due process violation was a discrete past event—the issuance of the notice and termination of benefits—not an ongoing violation. The court further held that the relief sought was retrospective, not prospective, and thus barred by the Eleventh Amendment. The court concluded that the Ex parte Young exception did not apply, and affirmed the dismissal. View "Filyaw v. Corsi" on Justia Law