Justia Public Benefits Opinion Summaries

Donald Thorpe sought disability benefits, claiming that his health issues rendered him unable to work. The Administrative Law Judge (ALJ) denied his claim, relying on the testimony of a vocational expert. Thorpe appealed to the district court, which affirmed the ALJ’s decision, stating that Thorpe forfeited any challenge to the expert testimony by failing to object timely and that the decision was supported by substantial evidence.The district court found that Thorpe did not object to the vocational expert’s testimony during the hearing or in a post-hearing brief, thus forfeiting his right to challenge it. The court also determined that the ALJ’s decision was based on substantial evidence, including the expert’s testimony, which was consistent with the Dictionary of Occupational Titles (DOT) and supported by the expert’s qualifications and experience.The United States Court of Appeals for the Seventh Circuit reviewed the case and agreed with the district court. The court held that Thorpe forfeited his ability to challenge the expert’s testimony by not objecting during the hearing. The court also found that the ALJ’s decision was supported by substantial evidence, as the expert’s testimony had sufficient indicia of reliability, including consistency with the DOT and the expert’s qualifications.The Seventh Circuit affirmed the district court’s decision, concluding that the ALJ did not err in relying on the vocational expert’s testimony to determine that Thorpe was not disabled and could find other gainful employment. View "Thorpe v Bisignano" on Justia Law

A skilled nursing facility accepted a new resident who was receiving Medicaid benefits. The resident's husband was designated as her authorized representative. Nearly two years later, the Department of Human Services (DHS) terminated the resident's Medicaid benefits due to excess assets. Both the resident and her husband were incapacitated, and the resident's public guardian submitted a new Medicaid application, which was denied. The nursing facility continued to care for the resident without compensation until her death. The facility later sought an administrative hearing to challenge the eligibility decision, but the request was denied because the facility was not an authorized representative and the appeal was late.The circuit court and the Intermediate Court of Appeals (ICA) affirmed the denial, holding that the nursing home lacked standing to challenge the eligibility determination under Hawai'i Revised Statutes (HRS) § 346-12, which limits appeals to the applicant or recipient. The courts concluded that the nursing home did not have a close relationship with the resident for third-party standing purposes.The Supreme Court of the State of Hawai'i reviewed the case and disagreed with the lower courts regarding standing. The court held that skilled nursing facilities have constitutionally protected property interests in compensation for medical services performed for residents based on DHS eligibility determinations. The court ruled that these facilities have due process rights under the Hawai'i Constitution, including notice and the opportunity to appeal Medicaid eligibility determinations when the beneficiary is incapacitated and no authorized representative is available or willing to appeal. The court vacated the ICA's judgment and the circuit court's order, remanding the case for a new administrative hearing on the merits of the resident's Medicaid eligibility. View "In re FT" on Justia Law

Dionne Marie Nadon applied for disability insurance benefits and supplemental security income in April 2015 and May 2016, respectively, citing conditions such as fibromyalgia, spinal abnormalities, depression, and anxiety. The administrative law judge (ALJ) initially denied her applications in January 2017, finding she could return to her past work as a cashier/checker. On appeal, the case was remanded because the ALJ had not adequately addressed Nadon’s post-traumatic stress disorder (PTSD). On remand, the ALJ again determined that Nadon was not disabled, following the five-step sequential analysis for determining disabilities.The ALJ found that Nadon had engaged in substantial gainful activity as a personal care attendant from July 2021 through 2022 but continued the analysis due to a continuous period of at least twelve months during which Nadon did not engage in substantial gainful activity. The ALJ found that Nadon had severe impairments but did not have an impairment or combination of impairments that met or equaled the severity of a listed impairment. The ALJ determined that Nadon’s residual functional capacity allowed her to perform light work with certain limitations and found that she could perform her past relevant work as a personal care attendant and other work as a housekeeper, marker, or small products assembler.The district court affirmed the ALJ’s decision. The United States Court of Appeals for the Ninth Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that the ALJ did not err by considering Nadon’s work as a personal care attendant, as an ALJ is permitted to consider any work done by a claimant when evaluating a disability claim. The court also found that the ALJ provided several reasons for discounting Nadon’s testimony and the opinions of several healthcare professionals, beyond her work as a personal care attendant. The court rejected Nadon’s argument that the ALJ erred by relying on the vocational expert’s testimony, as it relied on the rejected premise that the ALJ erred in discounting the healthcare professionals’ opinions. View "Nadon v. Bisignano" on Justia Law

Dawn Drumgold, a former employee of the Social Security Administration, applied for Social Security disability benefits in 2020, citing mental health issues including depression, bipolar disorder, and PTSD. Her application included medical records from her primary-care doctor, Dr. Sylvia Luther, and her mental-health counselor, Shideh Sarmadi, as well as reports from an independent examiner and two consultants. The records and reports provided conflicting assessments of her level of impairment.The Administrative Law Judge (ALJ) reviewed the evidence and found that Drumgold's limitations were moderate, not severe enough to qualify for disability benefits. The ALJ found Dr. Luther's records, which often noted that Drumgold's depression was in remission, more persuasive than Sarmadi's unsupported and conclusory submissions. The ALJ also found the reports from the two consultants, who concluded that Drumgold had only moderate limitations, to be consistent with the overall record.Drumgold appealed the ALJ's decision to the Social Security Appeals Council, which declined to reverse it. She then took her case to the United States District Court for the Eastern District of Virginia, which upheld the ALJ's decision, finding that it was supported by substantial evidence.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The court held that the ALJ had reasonably assessed the persuasiveness of the medical opinions based on their supportability and consistency with the overall record. The court found that substantial evidence supported the ALJ's conclusion that Drumgold's limitations were moderate and that she retained some capacity for work. View "Drumgold v. Commissioner of Social Security" on Justia Law

Rachael Gorecki applied for disability benefits and received a hearing before an administrative law judge (ALJ) whose appointment was ratified by Nancy Berryhill during her second tenure as Acting Commissioner of the Social Security Administration. The ALJ denied Gorecki's benefits application, and the Social Security Administration's Appeals Council denied review, making the decision final. Gorecki then sued, arguing that the ALJ had no constitutional authority to issue a decision because Berryhill's second stint as Acting Commissioner violated the Federal Vacancies Reform Act (FVRA).The United States District Court for the Northern District of Alabama rejected Gorecki's argument, aligning with other appellate courts that had ruled on similar issues. The district court found that Berryhill's second tenure as Acting Commissioner was lawful under the FVRA.The United States Court of Appeals for the Eleventh Circuit reviewed the case and joined five other circuits in holding that the FVRA authorized Berryhill's second stint as Acting Commissioner. The court found that the plain text of the FVRA allowed Berryhill to serve again as Acting Commissioner once a nomination for the office was submitted to the Senate, regardless of whether the nomination occurred during the initial 210-day period. The court affirmed the district court's judgment, concluding that Berryhill's ratification of the ALJ's appointment was valid and that the ALJ had the authority to deny Gorecki's benefits application. The Eleventh Circuit thus affirmed the lower court's decision. View "Gorecki v. Commissioner, Social Security Administration" on Justia Law

Ferida H. Moy suffers from severe PTSD due to her experiences during the Yugoslav Wars. She applied for disability insurance benefits and supplemental security income, citing her PTSD and related mental health issues. An administrative law judge (ALJ) denied her application, finding that she had the residual functional capacity to perform simple, routine tasks with minimal contact with supervisors and co-workers. This decision was upheld by the district court, leading Moy to appeal.The ALJ found that Moy had moderate limitations in concentrating, persisting, or maintaining pace but concluded that she could work at a consistent production pace. The ALJ's decision was based on the testimony of a vocational expert who stated that a person with Moy's limitations could work as a dining room attendant, bus person, scrap sorter, industrial cleaner, or dishwasher. However, the vocational expert also testified that regular absences or being off-task for more than 15% of the workday would result in job loss. The ALJ's decision was affirmed by the district court.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the ALJ failed to build a logical bridge between Moy's limitations and the conclusion that she could work at a consistent production pace. The court noted that the ALJ's determination did not adequately account for Moy's limitations in concentration, persistence, and pace. The court emphasized that the ALJ's reasoning was internally inconsistent and did not reflect Moy's documented symptoms and treatment needs. Consequently, the Seventh Circuit vacated the judgment and remanded the case to the Commissioner of Social Security for further consideration consistent with its opinion. View "Moy v Bisignano" on Justia Law

Plaintiff-Appellant Mollie Marie Flinton applied for Social Security disability insurance and supplemental security income benefits in August 2015, citing mental health disabilities. Her application was initially denied, and she requested an administrative hearing. ALJ Mark Solomon, who was not properly appointed at the time, conducted the hearing and denied her benefits in March 2018. Flinton appealed, and the United States District Court for the Southern District of New York remanded the case for a new hearing in 2020. Despite the remand, Flinton appeared again before ALJ Solomon in August 2021, whose appointment had been ratified by then.The United States District Court for the Southern District of New York, presided over by Magistrate Judge Gary R. Jones, granted a motion for judgment on the pleadings in favor of the Commissioner of Social Security in September 2023. The court found that the ALJ’s decision was supported by substantial evidence and that remanding the case to a new ALJ was unnecessary, despite acknowledging the Appointments Clause challenge.The United States Court of Appeals for the Second Circuit reviewed the case and held that, pursuant to Lucia v. SEC, Flinton was entitled to a new hearing before a different, properly appointed ALJ. The court found that ALJ Solomon’s initial decision was invalid due to his improper appointment and that the subsequent hearing before the same ALJ did not cure the constitutional violation. The court vacated the district court’s decision and remanded the case to the Commissioner for a de novo hearing before a different, validly appointed ALJ. View "Flinton v. Comm'r of Soc. Sec." on Justia Law

Christopher Obrien applied for disability insurance benefits and supplemental security income, claiming various medical conditions rendered him disabled since August 2010. He reported past work as a telemarketer in 2003 and 2009 and as a door-to-door salesperson in 2013 and 2014. The Social Security Administration (SSA) denied his claim, and an Administrative Law Judge (ALJ) upheld this decision, concluding Obrien could perform his past relevant work as a telemarketer and sales representative.Obrien challenged the ALJ's decision in the United States District Court for the Central District of California, arguing his telemarketing work was too old or insubstantial to count as past relevant work. The Commissioner conceded that substantial evidence did not support the ALJ's finding regarding Obrien's ability to perform his past work as a sales representative. However, the district court upheld the denial of benefits, finding Obrien's objections to the ALJ's determination regarding his telemarketing work both forfeited and meritless.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court rejected the Commissioner's argument that Obrien had forfeited his objections by not raising them before the ALJ, noting that SSA ALJ hearings are informal and nonadversarial, and ALJs are required to fully investigate the issues. The court held that substantial evidence did not support the ALJ's determination that Obrien's telemarketing work in 2003 and 2009 counted as past relevant work. The 2003 work was outside the 15-year period required by the regulations, and there were ambiguities regarding the average monthly wages for the 2009 work, necessitating further record development by the ALJ.The Ninth Circuit reversed the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "OBRIEN V. BISIGNANO" on Justia Law

Alicia Rae Pufahl applied for disability insurance benefits from the Social Security Administration in August 2012, citing limitations due to Wegener’s granulomatosis, depression, pulmonary disease, back injury, bipolar disorder, and excessive fatigue. She needed to establish disability between August 8, 2011, and December 31, 2016. Her application was initially denied in November 2012, followed by several unfavorable decisions from Administrative Law Judges (ALJs), appeals, and remands. The most recent ALJ decision concluded that she was not disabled during the relevant period, and the district court affirmed this decision.The United States District Court for the Eastern District of Wisconsin affirmed the ALJ’s decision, finding that substantial evidence supported the agency’s determination. The Appeals Council denied further review, making the ALJ’s decision the final decision of the Commissioner of Social Security.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The court held that the ALJ properly weighed the medical opinion evidence, including the opinions of Ms. Pufahl’s neurologist, primary care provider, and psychiatrist, and found substantial evidence supporting the ALJ’s decision to not give controlling weight to these opinions. The ALJ’s evaluation of Ms. Pufahl’s subjective complaints was not patently wrong, as it was supported by specific reasons and evidence. Additionally, the hypothetical question posed to the vocational expert (VE) sufficiently accounted for Ms. Pufahl’s mental limitations, including her ability to maintain attention and concentration for two-hour segments. The court concluded that the ALJ’s decision was supported by substantial evidence and affirmed the district court’s judgment. View "Pufahl v Bisignano" on Justia Law

Albert Lobo, a Deputy Sheriff in San Bernardino County, California, contracted pneumonia in early 2010, which progressed to sepsis and resulted in multiple amputations, leaving him permanently and totally disabled. He received disability retirement and workers' compensation benefits at the county and state levels between 2012 and 2014. In March 2015, Lobo filed a claim for disability-based benefits under the Public Safety Officers’ Benefits Act of 1976 (PSOB Act) with the Public Safety Officers’ Benefits Office (PSOB Office) of the Bureau of Justice Assistance (Bureau) of the U.S. Department of Justice.The PSOB Office denied Lobo's claim in May 2016, a decision upheld by a hearing officer in October 2017 and the Bureau’s Director in August 2023. The denials were based on the finding that Lobo had not proven he contracted pneumonia in the line of duty. The Bureau's Director emphasized the lack of evidence showing that Lobo caught pneumonia at the jails where he worked, despite acknowledging that Lobo was permanently and totally disabled due to pneumonia.The United States Court of Appeals for the Federal Circuit reviewed the case. The court found that the Bureau had not made sufficient efforts to obtain potentially crucial information about whether there were pneumonia-infected individuals at the jails where Lobo worked. The court noted that such information could be highly material to determining the origin of Lobo's pneumonia. Consequently, the court vacated the Director’s decision and remanded the case for further proceedings, instructing the Bureau to make reasonable efforts to obtain the necessary information from the jails and to reassess the claim in light of any new evidence obtained. View "Lobo v. Department of Justice" on Justia Law