Justia Public Benefits Opinion Summaries

A claimant applied for disability insurance benefits and supplemental security income, alleging a range of physical and mental health impairments. After an initial denial and an earlier remand from the district court, the claimant appeared before a new administrative law judge (ALJ). At the hearing, a vocational expert (VE) testified about the number of jobs in the national economy that someone with the claimant’s limitations could perform. The VE identified three specific jobs and provided job-number estimates, relying on sources such as SkillTRAN and manufacturer databases. The claimant then submitted post-hearing objections and contrary job-number evidence, using similar data sources, including SkillTRAN and the U.S. Census Bureau, to show far fewer available jobs or, in some cases, none at all.The ALJ briefly acknowledged the claimant’s contrary evidence but found it unpersuasive, stating that the VE’s testimony was more reliable due to his professional experience. The Appeals Council denied review, and the claimant then challenged the decision in the United States District Court for the District of Oregon. The district court affirmed, reasoning that the claimant’s alternative job numbers lacked probative value because the evidence did not sufficiently explain the methodology or expertise involved in generating those numbers.On appeal, the United States Court of Appeals for the Ninth Circuit found that the claimant’s counter evidence was both significant and probative, as it was generated using data sources and methods frequently relied upon by the Social Security Administration and showed large discrepancies with the VE’s estimates. The Ninth Circuit held that the ALJ erred by failing to adequately address and resolve the inconsistencies between the competing job-number evidence. The court reversed the district court’s decision and remanded the matter to the agency for further proceedings to resolve these discrepancies. View "POWLEY V. BISIGNANO" on Justia Law

A deputy sheriff employed by the Rhode Island Department of Public Safety applied for both ordinary and accidental disability retirement pensions, claiming a back injury sustained in 2011 caused him to stop working in 2020. The Employees’ Retirement System of Rhode Island’s Disability Committee recommended approval of only the ordinary disability pension, finding the accidental disability claim untimely under the statutory filing limits, and noting no evidence of an intervening injury or aggravation. The state retirement board adopted this recommendation and denied the accidental disability pension. Despite submitting additional evidence and requesting rehearing and further medical evaluation, the deputy sheriff’s application continued to be denied by the board, which advised that any appeal could be made in the Superior Court or the Workers’ Compensation Court, if applicable.Following these denials, the deputy sheriff filed appeals in both the Superior Court and the Workers’ Compensation Court. The Employees’ Retirement System moved to dismiss the Workers’ Compensation Court matter, arguing that the court lacked jurisdiction over a state employee’s appeal. The trial judge of the Workers’ Compensation Court denied the motion, concluding that jurisdiction existed based on multiple statutes, including those relating to injured-on-duty payments and the right to appeal denials of accidental disability pensions.The Supreme Court of Rhode Island reviewed the case on certiorari and held that the Workers’ Compensation Court did not have subject matter jurisdiction to hear the deputy sheriff’s appeal. The Court reasoned that the statutory scheme provides for Workers’ Compensation Court jurisdiction only for municipal employees covered under the Optional Retirement Plan, not for state employees like the petitioner, who are covered by the state retirement system. The Supreme Court therefore quashed the trial judge’s order and remanded the case for dismissal due to lack of jurisdiction. View "O'Connell v. Employees' Retirement System of Rhode Island" on Justia Law

Several individuals who participate in West Virginia’s Medicaid program and have been diagnosed with gender dysphoria sought surgical treatments that are excluded from coverage under West Virginia’s Medicaid plan. The state plan expressly excludes coverage for “sex change” or “transsexual” surgeries, though it covers these procedures for other medical indications, such as cancer or congenital abnormalities. The plaintiffs, representing a class of similarly situated individuals, alleged that this exclusion discriminates against them in violation of the Equal Protection Clause, Section 1557 of the Affordable Care Act, and certain provisions of the Medicaid Act.In proceedings before the United States District Court for the Southern District of West Virginia, the court granted summary judgment to the plaintiffs on all claims. The court found that the exclusion was unlawful under the Equal Protection Clause, the Affordable Care Act’s anti-discrimination provision, and the Medicaid Act’s comparability and availability requirements. The district court issued a declaratory judgment and enjoined enforcement of the exclusion. On appeal, the United States Court of Appeals for the Fourth Circuit sitting en banc affirmed the district court’s judgment. The state defendants then sought review by the Supreme Court, which granted certiorari, vacated the Fourth Circuit’s en banc decision, and remanded for reconsideration in light of two recent Supreme Court cases: United States v. Skrmetti and Medina v. Planned Parenthood South Atlantic.Upon reconsideration, the United States Court of Appeals for the Fourth Circuit reversed the district court. The court held that, under Skrmetti, West Virginia’s exclusion does not violate the Equal Protection Clause or the Affordable Care Act, because the exclusion is based on medical diagnosis rather than sex or transgender status and is supported by rational, non-discriminatory reasons. Applying Medina, the court further held that the Medicaid Act’s comparability and availability requirements do not provide a private right of action, and thus plaintiffs could not sue under those provisions. The Fourth Circuit reversed and remanded the case with instructions to enter summary judgment for the defendants. View "Anderson v. Crouch" on Justia Law

Roger Mullins, a coal miner, filed a claim for Black Lung benefits in 2012, asserting he was totally disabled due to pulmonary disease caused by coal dust exposure. His initial claim was denied. In 2019, Mullins sought modification of the denial, alleging a mistake of fact and a change in conditions. During the modification proceedings, Mullins submitted new evidence, including medical reports, pulmonary function tests, and treatment records. His medical experts attributed his total disability to legal pneumoconiosis, a chronic pulmonary condition substantially aggravated by coal dust exposure. Cedar Coal Company, his last coal mine employer, contested this, arguing that his impairment was due to other causes such as asthma, obesity, and coronary bypass surgery.An Administrative Law Judge (ALJ) heard the case and determined that Mullins was totally disabled due to legal pneumoconiosis, awarding Black Lung benefits. The ALJ gave greater weight to the medical opinion of Dr. Go, Mullins’ expert, over those of the employer’s experts, finding Dr. Go’s interpretation of the evidence more persuasive and his experience more relevant. Cedar Coal Company appealed this decision to the Benefits Review Board, which affirmed the ALJ’s award of benefits.The United States Court of Appeals for the Fourth Circuit reviewed the case. Cedar Coal Company argued that Mullins exceeded the regulatory limitations on affirmative medical evidence and that the ALJ’s finding of legal pneumoconiosis was not supported by substantial evidence. The Fourth Circuit rejected both arguments. It held that the ALJ properly considered all admissible evidence, including treatment records and expert analysis, without violating evidentiary limits. The court found the ALJ’s factual determinations were supported by substantial evidence and adequately explained. The petition for review was denied, and the award of benefits was affirmed. View "Cedar Coal Company v. DOWCP" on Justia Law

A participant in the federal Section 8 housing assistance program received notice from the local housing authority that her benefits would be terminated based on several alleged violations, including a recent eviction for serious lease violations, untimely submission of eligibility documentation, failure to allow an inspection, and failure to maintain her unit. The participant contested the termination, explaining that her appeal of the eviction was still pending and that she ultimately complied with inspection and paperwork requirements.At the administrative hearing, the hearing officer concluded that because a court-ordered eviction had occurred and, according to the officer, had been upheld on appeal, termination of assistance was mandatory under federal regulations. The participant then petitioned the Superior Court of Riverside County for a writ of administrative mandamus, arguing that the finding regarding her eviction was factually incorrect, as the appeal was still pending. Soon after, the appellate division of the Riverside County Superior Court reversed the eviction judgment for insufficient evidence. The trial court acknowledged that the hearing officer’s findings regarding the eviction were not supported by the record. However, it proceeded to independently review the evidence and found other violations of program obligations, upholding the housing authority’s discretionary decision to terminate benefits.The California Court of Appeal, Fourth Appellate District, Division Two, found that the trial court misunderstood the scope of judicial review under Code of Civil Procedure section 1094.5. The appellate court held that the trial court was required to review whether the administrative agency’s factual findings—not any alternative grounds—were supported by the record. Since the hearing officer’s findings were unsupported and the court could not uphold termination based on new grounds not adjudicated at the administrative hearing, the judgment was reversed with instructions to grant the petition and vacate the termination of assistance. View "Harrington v. Housing Authority of Riverside County" on Justia Law

Caroline McCall was employed for over twenty years as a Clinical Systems Coordinator at a hospital, where her responsibilities evolved to include inventory management, IT systems, and various administrative tasks. Over time, her duties increased and she began to suffer from bilateral carpal tunnel syndrome, which medical professionals attributed to her intense hand activity at work. Despite undergoing two surgeries and being prescribed specific workplace accommodations, her employer failed to provide some of these adjustments. After her pain worsened and her responsibilities continued to grow, McCall resigned in December 2020, citing physical and mental exhaustion due to her condition.Following her resignation, McCall applied for temporary total disability benefits under the D.C. Workers’ Compensation Act. An Administrative Law Judge (ALJ) found her testimony and the medical evidence credible, determining that her carpal tunnel syndrome was work-related and that she was unable to perform her job due to insufficient accommodations. The ALJ awarded her temporary total disability benefits. The Compensation Review Board (CRB) affirmed the ALJ’s order, agreeing that the correct legal standard was applied and that substantial evidence supported the findings. The employer challenged the CRB’s decision, arguing that the wrong time frame was used to assess her ability to perform her “usual job,” that the findings were not supported by substantial evidence, and that the ALJ failed to address whether McCall voluntarily retired for reasons unrelated to her disability.The District of Columbia Court of Appeals reviewed the case and affirmed the CRB’s decision. The court held that the CRB applied the correct legal standard by considering McCall’s job duties at the time of her resignation, that substantial evidence supported the finding of temporary total disability, and that McCall’s resignation was causally related to her work injury rather than being a voluntary limitation of income for unrelated reasons. View "Howard v. D.C. Department of Employment Services" on Justia Law

A former employee of the County of San Diego pleaded guilty to a felony charge for violating a state conflict-of-interest law, which prohibits public employees from having a financial interest in contracts made in their official capacity. After the guilty plea, but before sentencing, the San Diego County Employees Retirement Association (SDCERA) notified him that a portion of his accrued pension benefits would be forfeited under Government Code section 7522.74, as he had been “convicted” of a job-related felony. At sentencing, the criminal court reduced the offense to a misdemeanor under Penal Code section 17, subdivision (b)(3). The employee then requested reinstatement of his pension benefits, which SDCERA denied.The employee challenged SDCERA’s denial through administrative appeals, including to its chief executive officer and Board of Retirement, but both appeals were denied. He subsequently petitioned the Superior Court of San Diego County for a writ of administrative mandate to set aside SDCERA’s decision. The court denied the petition, finding that section 7522.74 precluded reinstatement of the forfeited pension benefits. The employee timely appealed the judgment.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that a public employee is “convicted” for purposes of Government Code section 7522.74 upon an adjudication of guilt—whether by plea or jury verdict—and not only upon entry of judgment. The reduction of the felony to a misdemeanor at sentencing under Penal Code section 17, subdivision (b)(3), did not retroactively affect the forfeiture. The court affirmed the judgment, concluding that the employee’s pension benefits remained forfeited, and SDCERA properly denied reinstatement. View "Bishop v. San Diego County Employees Retirement Assn." on Justia Law

During a contentious divorce and custody dispute, Amanda Hovanec, who had returned to Ohio from South Africa with her children, conspired with Anthony Theodorou, her romantic partner, to kill her husband, T.H. After failed attempts to hire hitmen in South Africa, Theodorou, at Hovanec’s direction, obtained and shipped etorphine, a dangerous animal tranquilizer, to the United States. Hovanec ultimately used the drug to fatally inject T.H. at her mother Anita Green’s home. Green assisted after the murder by helping to select a burial site, driving the others to dig a grave, and later transporting them and the body for burial. The group also undertook efforts to conceal the crime, including disposing of T.H.’s belongings and misleading authorities. All three were arrested after an investigation revealed dashcam footage of the crime.In the United States District Court for the Northern District of Ohio, Hovanec pleaded guilty to multiple controlled-substance offenses resulting in death, and Green pleaded guilty to being an accessory after the fact. Hovanec received a 480-month sentence; Green received 121 months and was ordered to pay restitution for psychological care for T.H.’s and Hovanec’s children. Both defendants appealed their sentences and, in Green’s case, the restitution order.The United States Court of Appeals for the Sixth Circuit affirmed the sentences for both Hovanec and Green. The appellate court upheld the denial of a sentencing reduction for Green based on her lack of candor regarding knowledge of the murder plan. The court also affirmed the sentencing enhancements for Hovanec’s leadership role and obstruction of justice. However, the court reversed the restitution order against Green, holding that under federal law, restitution for psychological care requires evidence of bodily injury, defined as physical harm or physical manifestations of psychological harm, and remanded for further factual findings on this issue. View "United States v. Green" on Justia Law

The plaintiff, who has a disability, took the New Mexico bar exam in February 2020 and was approved for testing accommodations. She alleged that these accommodations were not properly provided during the exam. Subsequently, she initiated legal action, amending her complaint multiple times before any defendant appeared. The third amended complaint asserted claims under Titles II and III of the Americans with Disabilities Act (ADA), § 504 of the Rehabilitation Act, and other federal and state laws.The United States District Court for the District of New Mexico dismissed all claims. Specifically, it dismissed claims against the National Conference of Bar Examiners (the National Conference) for lack of personal jurisdiction, and permitted amendment of the complaint only to allow a Title III ADA claim against the New Mexico Board of Bar Examiners (the State Board). The district court later dismissed the Title III claim against the State Board on Eleventh Amendment sovereign immunity grounds. It also granted summary judgment to the State Board on the Rehabilitation Act claim, finding the Board did not receive federal funds, and denied the plaintiff’s requests for additional discovery as insufficient under Rule 56(d).On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s judgment. The court held that the plaintiff had not properly preserved her entitlement to jurisdictional discovery regarding the National Conference, nor did she adequately request or specify discovery that could alter the personal jurisdiction determination. The court also found no abuse of discretion in denying additional discovery on the Rehabilitation Act claim, as the plaintiff failed to meet procedural requirements. Finally, the Tenth Circuit concluded that the State Board was protected by Eleventh Amendment immunity from Title III ADA claims and that the plaintiff failed to show any waiver or valid abrogation of immunity. The judgment below was affirmed. View "Spann v. National Conference of Bar Examiners" on Justia Law

The plaintiff applied for disability benefits from the Social Security Administration (SSA) but was denied at the agency level. She then sought judicial review in the United States District Court for the Northern District of Ohio. After the Commissioner of Social Security reviewed the case further, the Commissioner moved to remand the matter to the Administrative Law Judge (ALJ) for additional proceedings, specifically for further articulation regarding the persuasiveness of the evidence and further consideration of medical opinions. The Commissioner did not argue that the ALJ committed reversible error. The plaintiff agreed to a remand but requested that the court issue instructions to award her benefits outright.The district court granted the Commissioner’s motion for remand, reasoning that factual disputes remained and that it was not prepared to award benefits. The court remanded the case to the SSA for further consideration without affirming, modifying, or reversing the ALJ’s decision, and without expressly finding reversible error or making the specific predicate findings required for a remand under Sentence Six of 42 U.S.C. § 405(g). The plaintiff appealed the district court’s order.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that a district court may not remand a Social Security case under Sentence Four of 42 U.S.C. § 405(g) without explicitly affirming, modifying, or reversing the decision of the ALJ. The appellate court found that the district court’s order failed to comply with the requirements of either Sentence Four or Sentence Six and that district courts do not have inherent authority to issue other types of remand orders in Social Security cases. The Sixth Circuit therefore vacated the district court’s order and remanded the matter for further proceedings consistent with the opinion. View "Follen v. Commissioner of Social Security" on Justia Law