Justia Public Benefits Opinion Summaries

The Eighth Circuit affirmed the district court's order upholding the Commissioner's denial of social security disability insurance benefits (DIB). The court concluded that substantial evidence supported the determination that plaintiff's impairments did not meet or medically equal Listing 11.09B or 12.02. In this case, plaintiff's mental impairment did not cause at least two marked limitations or one extreme limitation, as required by the paragraph B criteria for Listing 12.02. Furthermore, although plaintiff's medical records revealed several minor deficiencies, such as a subtle tremor in her left hand and mild executive dysfunction, those records did not indicate a marked limitation in physical functioning and one of the four areas of mental functioning as required by Listing 11.09B. View "Schmitt v. Kijakazi" on Justia Law

Three teaching hospitals challenged the denial of Medicare reimbursements. At that time, a teaching hospital could obtain reimbursement only by incurring “substantially all” of a resident’s training costs. Because the teaching hospitals had shared the training costs for each resident, the government denied reimbursement. The denials led the teaching hospitals to file administrative appeals. While they were pending, Congress enacted the Affordable Care Act (ACA), which created a new standard for reimbursement. The parties disagreed on whether the ACA’s new standard applied to proceedings reopened when Congress changed the law. The agency answered no, and the district court granted summary judgment to the agency. Finding no reversible error in that decision, the Tenth Circuit affirmed. View "St. Francis Hospital, et al. v. Becerra" on Justia Law

In 2009, Grotts applied for Social Security disability benefits, citing depression and low functional capacity. She had previously worked as a caretaker for a child with disabilities and he cared for her own child. Her case was remanded four times. Five times, an ALJ concluded that Grotts was not disabled. The final ALJ found that she could still perform light work with some restrictions and because a significant number of jobs fitting that description existed in the national economy.The district court agreed. The Seventh Circuit affirmed, rejecting arguments that the ALJ erred in its evaluation of Grotts’s subjective complaints about her symptoms, in its evaluation of the medical opinion evidence, and in its residual functional capacity determination. Substantial evidence supported the ALJ’s weighing of the medical opinion evidence and its RFC determination. The ALJ did not patently err in its evaluation of Grotts’s subjective complaints. View "Grotts v. Kijakazi" on Justia Law

Brooke Rojas was convicted of two counts of theft based on her improper receipt of food stamp benefits. Rojas initially applied for food stamp benefits from the Department of Human Services in August 2012 when she had no income. She received a recertification letter in December, which she submitted in mid-January 2013, indicating that she still had no income. And although she had not yet received a paycheck when she submitted the recertification letter, Rojas had started a new job on January 1. Rojas continued receiving food stamp benefits every month until July, when she inadvertently allowed them to lapse. She reapplied in August 2013. Although still working, Rojas reported that she had no income. The Department checked Rojas’s employment status in connection with the August application and learned that she was making about $55,000 a year (to support a family of seven). The Department determined that Rojas had received $5,632 in benefits to which she was not legally entitled. At trial, Rojas’s defense was that she lacked the requisite culpable mental state—she didn’t knowingly deceive the government; she just misunderstood the forms. Before trial, Rojas objected to the prosecution’s proposed admission of the August 2013 application because it exceeded the time period of the charged offenses and didn’t lead to the receipt of any benefits. The prosecution countered that the application was admissible as res gestae evidence—to show how the investigation began—and as evidence of specific intent. The court found it relevant as circumstantial evidence of Rojas’s mental state. In its opinion issued upon Rojas' appeal, the Colorado Supreme Court concluded it was "time for us to bury res gestae. ... By continuing to rely on res gestae as a standalone basis for admissibility and allowing the vagueness of res gestae to persist next to these more analytically demanding rules of relevancy, we have created a breeding ground for confusion, inconsistency, and unfairness." The Court's decision to abolish the res gestate doctrine in criminal cases prompted it to reverse judgment and remand for a new trial. View "Rojas v. Colorado" on Justia Law

The Supreme Court affirmed the judgment of the circuit court determining what portion of a settlement was subject to the Commonwealth's Medicaid lien, holding that there was no error.Appellant was seriously injured in a car accident. Because the Commonwealth's Medicaid program paid for a portion of Appellant's medical care the Commonwealth was entitled to a lien on the proceeds of an ensuing settlement between Appellant and the driver who caused the accident. At issue was what portion of the settlement was subject to the Medicaid lien. The Supreme Court affirmed, holding that the circuit court's judgment was proper under the deferential standard. View "Farah v. Commonwealth" on Justia Law

After working underground in coal mines for three decades, Casey developed pneumoconiosis (black-lung disease). His widow, Mabel, sought benefits under the Black Lung Benefits Act, 30 U.S.C. 901–44. It took the Department of Labor 17 years to deny her claims. During this time, the claims bounced back and forth between an ALJ and the Benefits Review Board. In the last appeal, the Board also rejected one of Mabel’s main arguments, citing “law-of-the-case,” without reaching the merits. The Department of Labor then delayed things further by filing an incomplete and disorganized administrative record in the Sixth Circuit.The Sixth Circuit affirmed. While the government’s actions “perhaps could be described as poor customer service, they do not show any reversible legal error.” The Board could lawfully invoke the discretionary law-of-the-case doctrine to avoid reexamining an issue on which it had affirmed the ALJ years before. The credibility findings concerning the conflicting medical opinions concerning whether Casey was totally disabled or had only “moderate impairment” pass muster under the deferential “substantial evidence” test. View "Samons v. National Mines Corp." on Justia Law

Mandrell, born in 198, pursued her education through one year in college. In 2005-2009, she served in the Coast Guard, which she left with an honorable discharge. While in service she was the victim of a rape by a fellow service member. She developed PTSD and anxiety afterward. The VA found her to be 100% disabled based on a service-related cause and awarded benefits but later revised her level of disability down to 70%. Mandrell’s 2017 application for Social Security disability benefits was denied and the Appeals Council denied her request for review. The district court affirmed.The Seventh Circuit reversed and remanded. The ALJ failed to connect the residual functional capacity he found with the evidence in the record, and he did not adequately account for her deficits in concentration, persistence, and pace. The ALJ apparently accepted that Mandrell suffered from PTSD as a result of the rape, but dismissed most of the symptoms that accompanied that condition. While the Social Security Administration is not bound by the VA’s assessment of Mandrell’s disability, the underlying medical evidence on which the VA relied is just as relevant to the social‐security determination as it was to the VA. View "Mandrell v. Kijakazi" on Justia Law

Plaintiffs-appellees Ronda Owens, Darryl Hubbard, Selena Freymiller, Shanika Crowley, Valerie Killman, Michael Lee Pitts, Ebony Warrior, John Ball, Michelle Bullock, Logan Bellew, Sondia Bell, Tumeeka Baker, and Jay Reid (collectively "Citizens") filed the underlying lawsuit seeking declaratory and injunctive relief. Citizens claimed that Oklahoma Governor J. Kevin Stitt and Defendant-appellant Shelley Zumwalt, in her official capacity as Executive Director of the Oklahoma Employment Security Commission, acted without authority and violated 40 O.S.2011 section 4-313 of the Oklahoma Employment Security Act by terminating agreements with the U.S. Department of Labor to administer COVID-related unemployment programs. The trial court entered a preliminary injunction ordering Zumwalt to immediately reinstate and administer the programs. Zumwalt appealed, and the Oklahoma Supreme Court stayed the trial court's order pending appeal. The Supreme Court found 40 O.S. 4-313 did not create a private right of action and, therefore, the trial court abused its discretion by granting a preliminary injunction. View "Owens, et al. v. Zumwalt" on Justia Law

Reynolds, born in 1992, graduated from high school and previously worked part-time in retail. Reynolds suffers from migraines, vertigo, and “major depressive disorder, recurrent moderate with anxious distress.” She applied for Social Security disability benefits in 2017. Reynolds testified that she suffers from back pain, vertigo, and migraines, and she cannot stand for more than 10 minutes. Her parents handle household chores. She has migraines every day. She stopped taking some prescription medications for her migraines because of the side effects. Reynolds quit her job at Walmart because of her migraines. Reynolds testified has never gone to an emergency room or crisis center for mental health treatment but suffers from anxiety around “more than five people.” She was taking medication for her mental health conditions.The ALJ concluded that Reynolds was not disabled under the Social Security Administration’s five-step method and that Reynolds had the residual functional capacity to perform a full range of work with certain non-exertional limitations. The Seventh Circuit affirmed the denial as supported by substantial evidence. The court rejected an argument that the ALJ erred by failing to include a qualitative interaction limitation in the residual functional capacity determination. No medical evidence called for a qualitative interaction limitation; the ALJ was not required to intuit such a limitation from the administrative record. View "Reynolds v. Kijakazi" on Justia Law

The issue this case presented for the New Jersey Supreme Court's review in this appeal was who bore the primary responsibility for the payment of Dale Mecouch’s medical bills arising from an automobile accident that took place before December 5, 1980: the issuer of an automobile insurance policy or Medicare. In 2016, Mecouch was hospitalized for approximately two months at Cooper Hospital University Medical Center (Cooper) due to complications arising from a 1977 automobile accident that left him paralyzed from the waist down. At the time of his accident, Mecouch had a no-fault automobile insurance policy with Selective Insurance Company of America (Selective), which provided Mecouch with unlimited personal-injury-protection (PIP) benefits. Sometime after 1979 but before 2016, Mecouch was enrolled in Medicare. Selective continued to pay Mecouch’s medical expenses related to the 1977 accident until December 11, 2015, when it notified Mecouch by letter that, going forward, “Medicare is the appropriate primary payer for any treatment related to” the 1977 accident. After Mecouch’s 2016 hospital stay, Cooper forwarded to Selective a bill for over $850,000 for medical services rendered to Mecouch. Instead of paying that bill, Selective directed Cooper to seek reimbursement from Medicare. Cooper was a participating Medicare provider, and, at that time, Mecouch was a Medicare enrollee. Cooper then billed Medicare, which issued a payment of under $85,000. Selective eventually agreed to reimburse Cooper for Mecouch’s co-payments and deductibles. Cooper filed a complaint against Selective, seeking the total cost of Mecouch’s care. The trial court granted summary judgment in favor of Cooper, awarding Cooper the cost of Mecouch’s care minus the amount covered by Medicare. The Appellate Division reversed, concluding Medicare was the “primary payer” for Mecouch's medical bills at Cooper. The Supreme Court concluded that because Mecouch was a Medicare enrollee in 2016, Cooper was required to bill and accept payment from Medicare, which promptly covered Mecouch’s medical expenses in accordance with its fee schedule. Cooper could not seek payment from Selective other than for reimbursement of the Medicare co-payments and deductibles. View "Cooper Hospital University Medical Center v. Selective Insurance Company of America" on Justia Law