Justia Public Benefits Opinion Summaries

An Army veteran serving a lengthy prison sentence in Florida applied for and received disability benefits for service-related post-traumatic stress disorder. Initially, the Veterans Benefits Administration approved his claim at a 70 percent rate, later increasing it to 80 percent. However, after his felony conviction and incarceration, the Administration reduced his monthly benefits to a 10 percent rate pursuant to 38 U.S.C. § 5313, which limits disability payments for veterans incarcerated for more than 60 days due to a felony.The veteran filed a pro se complaint in the United States District Court for the Middle District of Florida, naming the United States Congress as defendant. He alleged that the statute reducing his benefits violated the Bill of Attainder Clause and the Equal Protection component of the Fifth Amendment, seeking both prospective and retroactive relief. A magistrate judge recommended dismissal, assuming without deciding that the court had jurisdiction over facial constitutional challenges, but finding the claims frivolous. The district court adopted this recommendation, dismissing the complaint and declining to address the plaintiff’s general objections.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that sovereign immunity barred the suit against Congress, as Congress has not waived immunity for constitutional claims arising from its enactment of legislation. The court further held that any amendment to name a different defendant would be futile because the Veterans’ Judicial Review Act provides an exclusive review scheme for challenges to veterans’ benefits decisions, channeling all such claims—including constitutional challenges—through the administrative process and ultimately to the Court of Appeals for Veterans Claims and the Federal Circuit. The Eleventh Circuit vacated the district court’s judgment and remanded with instructions to dismiss the case without prejudice for lack of jurisdiction. View "Johnson v. United States Congress" on Justia Law

A childcare provider operating two centers in Vermont participated in the federal Child and Adult Care Food Program (CACFP), which reimburses centers for meals provided to children if certain regulatory requirements are met. The provider had previously been cited for noncompliance in 2019, but the matter was resolved after corrective action. In 2022, the Vermont Agency of Education (AOE) again found serious deficiencies, including inadequate recordkeeping, improper meal claims, and failure to monitor facilities. The provider submitted a corrective-action plan, and AOE initially determined the deficiencies were fully and permanently corrected. However, a subsequent unannounced review in 2023 revealed recurring deficiencies, such as missing enrollment forms, incorrect eligibility determinations, and incomplete documentation.Following these findings, AOE issued a notice proposing to terminate the provider’s participation in CACFP and to disqualify the provider and two employees from future participation. The provider requested an administrative review. At the hearing, the provider acknowledged some paperwork was not in compliance but argued the errors were minor and unintentional. Due to time constraints, the hearing officer allowed both parties to submit post-hearing written arguments and documentation, to which the provider did not initially object but later challenged as a violation of due process and agency procedures.The Vermont Supreme Court reviewed the case after the hearing officer affirmed AOE’s decision to terminate and disqualify the provider. The Court held that the hearing officer applied the correct legal standard and that the record supported the findings of persistent serious deficiencies. The Court also determined that the provider had not properly preserved its objection to post-hearing submissions and, regardless, was not prejudiced by the procedure. The Court affirmed the termination and disqualification from the CACFP. View "In re Butterfly Kisses Child Care Center, Inc." on Justia Law

A healthcare provider participated in Kentucky’s Medicaid program, offering in-home services to recipients in rural areas under the Home and Community Based (HCB) Waiver program. The Department for Medicaid Services had, for several years, reimbursed the provider at enhanced rates for “case management” services, even though the relevant administrative regulation did not list “case management” as a reimbursable “revenue code service.” In 2016, the Department determined that these payments were made in error and sought to recoup over $1 million from the provider for services rendered between 2011 and 2013.After the Department initiated recoupment, the provider contested the action through the Cabinet’s administrative process, arguing that the omission of “case management” from the regulation was a drafting error and that the Department should be estopped from recouping the funds due to its prior representations and delay. The administrative hearing officer rejected these arguments, finding the regulation’s text unambiguous and concluding that neither equitable estoppel nor laches applied. The Secretary of the Cabinet adopted this decision. The provider then sought judicial review in the Franklin Circuit Court, which affirmed the agency’s decision. The Kentucky Court of Appeals also affirmed.The Supreme Court of Kentucky reviewed the case and affirmed the Court of Appeals. The Court held that the Department’s regulation unambiguously excluded “case management” from the list of services eligible for enhanced reimbursement, and the Department was within its authority to recoup the overpaid funds. The Court declined to read omitted language into the regulation, found no basis for equitable estoppel or laches against the Department, and rejected the provider’s arguments regarding the sufficiency of the Department’s audit. View "PROFESSIONAL HOME HEALTH CARE V. COMMONWEALTH OF KENTUCKY CABINET FOR HEALTH AND FAMILY SERVICES" on Justia Law

Two children, E.R. and G.S., have severe, complex medical conditions that require constant, skilled care. Their mothers, who are their primary caregivers and sole financial supporters, have been trained by medical professionals to provide the necessary care at home. For years, Indiana’s Medicaid program reimbursed these mothers for providing “attendant care services” under a waiver program designed to keep individuals out of institutions. In July 2024, the Indiana Family and Social Services Administration (FSSA) implemented a policy change that would make parents ineligible to be paid providers of attendant care for their children, threatening to force E.R. and G.S. into institutional care due to the lack of available in-home nurses.The Indiana Protection and Advocacy Services Commission, along with E.R. and G.S., sued to block the policy change and require FSSA to secure in-home nursing. The United States District Court for the Southern District of Indiana initially granted a preliminary injunction requiring FSSA to take steps to obtain in-home nurses and to pay the mothers for a different, lower-paid service. After further proceedings, the court modified its order, ultimately requiring FSSA to pay the mothers for attendant care at the previous rate until in-home nursing could be secured.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s October 1 injunction. The court held that the plaintiffs are likely to succeed on their claims under the Americans with Disabilities Act’s integration mandate, which requires states to provide services in the most integrated setting appropriate. The court found that prohibiting the mothers from providing paid attendant care placed the children at serious risk of institutionalization and that FSSA had not shown that allowing such care would fundamentally alter the Medicaid program or violate federal law. The case was remanded for further proceedings. View "Indiana Protection and Advocacy Services Comm'n v Indiana Family and Social Services Administration" on Justia Law

A certified registered nurse anesthetist, who had already retired and was receiving retirement benefits, resumed work at a medical center. He and other similarly situated salaried healthcare workers received additional pay for working undesirable shifts, such as weekends, holidays, late hours, on-call, and for hours worked beyond their scheduled shifts. This extra compensation, referred to as the "Wages in Controversy," was subject to mandatory deductions for the South Carolina Retirement System (SCRS). The plaintiff challenged these deductions, arguing that the extra pay should not be considered "earnable compensation" under the SCRS Act and thus should not be subject to retirement contributions.The United States District Court for the District of South Carolina, recognizing that the resolution of the plaintiff’s claims depended on the interpretation of state law, certified a question to the Supreme Court of South Carolina. The question was whether the Wages in Controversy constituted "earnable compensation" under South Carolina law, making them subject to mandatory employer deductions for SCRS contributions.The Supreme Court of South Carolina held that the Wages in Controversy are "earnable compensation" as defined by the SCRS Act. The court reasoned that these payments, although labeled differently by the employer, were all compensation for hours actually worked and not irregular, one-time, or bonus payments excluded by statute. The court concluded that such pay is subject to mandatory employer deductions under the relevant statutory provisions. The certified question was answered accordingly. View "Luce v. Lexington County Health Services District, Inc." on Justia Law

In 1994, Kenneth Hayes was murdered in Wayne County, Michigan. Larry Smith was convicted of first-degree murder and a firearm charge, largely based on the testimony of Edward Allen, a jailhouse informant who claimed Smith confessed to the crime. Smith’s conviction was affirmed on direct appeal, and his subsequent state and federal habeas petitions were unsuccessful. Years later, the Wayne County Prosecutor’s Conviction Integrity Unit investigated and found evidence suggesting Allen’s testimony may have been fabricated as part of a broader scheme involving police and prosecutors eliciting false testimony from informants. Smith’s conviction was vacated in 2021, and he was released from prison.After his release, Smith obtained compensation from the State of Michigan under the Wrongful Imprisonment Compensation Act (WICA), settling for $850,000 and signing a release of claims against the State. He then filed a federal lawsuit against Wayne County and prosecutor Robert Donaldson, alleging constitutional violations under 42 U.S.C. § 1983 and a Monell claim against the County for policies encouraging false testimony. The United States District Court for the Eastern District of Michigan granted summary judgment to both defendants, finding Donaldson was protected by absolute prosecutorial immunity and that Smith’s settlement under WICA released his claims against Wayne County.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. It held that Donaldson was entitled to absolute prosecutorial immunity because his conduct—preparing a witness for trial—was within the scope of his advocacy role, not investigatory. The court also held that Smith’s acceptance of the WICA settlement released all claims against Wayne County, including federal claims, as a matter of law. The Sixth Circuit affirmed the district court’s grant of summary judgment to both defendants. View "Smith v. Wayne County" on Justia Law

Jonathan Cain applied for supplemental security income (SSI) due to severe impairments, including degenerative disc disease, migraine headaches, obesity, depression, and anxiety. Despite his conditions, an administrative law judge (ALJ) determined that Cain could perform certain types of work and denied his disability benefits. Cain challenged this decision in federal court.The United States District Court for the Southern District of Indiana affirmed the ALJ's decision, holding that substantial evidence supported the ALJ's conclusion. The court found that the ALJ met the minimal articulation requirements in assessing the medical evidence and did not err in relying on the vocational expert's testimony.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the ALJ's decision was supported by substantial evidence. The ALJ adequately evaluated the medical opinions of Cain's treating physician, Dr. Amanda Williams, and the state agency psychologists, Dr. Joelle Larsen and Dr. Ken Lovko. The ALJ also properly relied on the vocational expert, Thomas Dunleavy, who provided a reliable basis for his job number predictions. The court concluded that the ALJ did not commit legal error and affirmed the district court's judgment. View "Cain v Bisignano" on Justia Law

Fletcher Properties, Inc. and other appellants own multi-tenant residential properties in Minneapolis. The City of Minneapolis enacted an ordinance prohibiting property owners from refusing to rent to individuals based on requirements of public assistance programs, including Section 8 housing vouchers. Fletcher challenged the ordinance, claiming it violated the Minnesota Constitution’s Takings Clause and was preempted by the Minnesota Human Rights Act (MHRA).The district court initially ruled in favor of Fletcher, finding the ordinance violated due process and equal protection clauses. The court of appeals reversed this decision, and the Minnesota Supreme Court affirmed, remanding the case to address the remaining claims. On remand, the district court granted summary judgment for the City, rejecting Fletcher’s takings and preemption claims. The court of appeals affirmed this decision, leading to the current appeal.The Minnesota Supreme Court reviewed the case and held that the ordinance does not constitute a physical or regulatory taking under the Minnesota Constitution. The court applied the Penn Central factors, concluding that the economic impact of the ordinance, interference with investment-backed expectations, and the character of the government action did not support a finding of a regulatory taking. The court also determined that the ordinance does not effect a physical taking as landlords voluntarily rent their properties and are not compelled to continue doing so.Additionally, the court held that the ordinance is not preempted by the MHRA. The court found no conflict between the ordinance and the MHRA, as the MHRA does not grant landlords an affirmative right to reject voucher holders. The court also concluded that the MHRA does not occupy the field of housing discrimination based on public assistance, allowing for local regulation.The Minnesota Supreme Court affirmed the decision of the court of appeals, upholding the ordinance. View "Fletcher Properties, Inc. vs. City of Minneapolis" on Justia Law

Jada Padua applied for Social Security benefits, claiming disability due to fibromyalgia, chronic fatigue, depression, and anxiety. An administrative law judge (ALJ) denied her benefits, concluding that she was not disabled as defined by the Social Security Act and that jobs existed in significant numbers in the national economy that she could perform. Padua challenged the agency’s denial in federal court, but the district court upheld the ALJ's decision, finding substantial evidence to support it.Padua filed her disability benefits application in November 2010, initially claiming a disability onset date of July 2008, later amended to November 2010. After an initial denial and a remand by a magistrate judge in February 2016, the ALJ held a second hearing in August 2016. The ALJ determined that Padua was not disabled under the Social Security Act, finding that her impairments did not meet a listing for presumptive disability and that she had the residual functional capacity (RFC) to perform light work with additional limitations. The ALJ discounted Padua’s complaints of extreme pain and fatigue, noting inconsistencies with her daily activities and the overall medical record. The ALJ also gave little weight to the opinions of her treating physicians, Drs. Carpenter and Pendolino, finding them inconsistent with the evidence.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The court held that the ALJ’s assessment of Padua’s fibromyalgia and the opinions of Drs. Carpenter and Pendolino were supported by substantial evidence. The court found that the ALJ reasonably considered the objective medical evidence, treatment history, and daily activities in determining Padua’s RFC. The court also concluded that the ALJ provided adequate reasons for discounting the treating physicians’ opinions and that the RFC determination was supported by substantial evidence. View "Padua v. Bisignano" on Justia Law

Christian Arnold retained Binder & Binder in April 2018 to represent him in a claim for disability benefits under the Social Security Act. After the Commissioner of Social Security denied his claim, Arnold appealed to the district court, which remanded the case to the agency. An administrative law judge later determined Arnold was entitled to $160,797.10 in past-due benefits. Binder then moved for attorneys' fees under 42 U.S.C. § 406(b), seeking twenty-five percent of the retroactive benefits, amounting to $40,199.27. The district court awarded Binder $16,920, reducing the fee based on an effective hourly rate of $600.The United States District Court for the Central District of Illinois initially awarded Binder $16,920, despite the contingency fee agreement. Binder appealed, and the United States Court of Appeals for the Seventh Circuit held that the district court abused its discretion by not anchoring its reasonableness analysis on the contingency fee agreement. The case was remanded for further proceedings. On remand, the district court again awarded $16,920, maintaining that the contingency fee should be reduced to reflect a more reasonable effective hourly rate. Binder appealed once more.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the district court abused its discretion by inadequately explaining its decision to reduce Binder’s fees. The appellate court emphasized that the district court must begin with the contingency fee agreement and consider relevant factors, such as the plaintiff’s satisfaction and the attorney’s expertise. The appellate court reversed the district court’s decision and remanded with instructions to order the Social Security Administration to remit attorneys’ fees at Binder’s requested amount of $34,199.27. View "Arnold v. Bisignano" on Justia Law