Justia Public Benefits Opinion Summaries

Joseph Fortin applied for disability insurance benefits, but his claim was denied by an Administrative Law Judge (ALJ) from the Social Security Administration (SSA). Fortin argued that the ALJ who denied his claim was improperly appointed because the then-Acting Commissioner of the SSA, Nancy Berryhill, lacked the authority to ratify the ALJ's appointment. Fortin did not challenge the merits of the ALJ's decision but focused on the validity of the ALJ's appointment.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the Commissioner of Social Security, rejecting Fortin's arguments. The court held that Berryhill's ratification of the ALJ's appointment was valid and that the ALJ did not err in denying Fortin's application for benefits.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Berryhill, as Acting Commissioner, had the authority to ratify the appointments of SSA ALJs in response to the Supreme Court's decision in Lucia v. Securities and Exchange Commission, which required ALJs to be appointed in accordance with the Appointments Clause. The court also concluded that Berryhill's actions were valid under the Federal Vacancies Reform Act and that she did not need to be reappointed by the sitting President to serve as Acting Commissioner. The court found that Berryhill's ratification of the ALJ's appointment was both constitutionally and statutorily valid, and therefore, Fortin was not entitled to a new hearing before a different ALJ. View "Fortin v. Commissioner of Social Security" on Justia Law

The case involves a class action lawsuit brought by several minor children, through their legal guardians, against the Commissioner of the Georgia Department of Community Health. The plaintiffs challenged the Department's practices regarding the provision of skilled nursing services under the Medicaid Act. Specifically, they contested the Department's use of a scoresheet to determine the number of skilled nursing hours and the practice of reducing those hours as caregivers learn to perform skilled tasks.The United States District Court for the Northern District of Georgia granted summary judgment in favor of the plaintiffs. The court ruled that the Department's review process did not give appropriate weight to the recommendations of treating physicians and that the practice of reducing skilled nursing hours as caregivers learn skilled tasks violated the Medicaid Act. The district court issued permanent injunctions requiring the Department to approve the skilled nursing hours prescribed by the patients' treating physicians.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court's decision. The appellate court held that the Department's review process, which includes the use of a scoresheet to determine a presumptive range of skilled nursing hours, complies with the Medicaid Act. The court also found that the practice of reducing skilled nursing hours as caregivers learn skilled tasks is reasonable and does not violate the Act. The court vacated the permanent injunctions and remanded the case for further proceedings. The appellate court did not address the plaintiffs' challenge regarding the consideration of caregiver capacity, as the district court had ruled that issue moot. The appeal of the preliminary injunctions was deemed moot following the vacatur of the permanent injunctions. View "M.H. v. Commissioner, Georgia Dept. of Community Health" on Justia Law

John Doe, a recipient of vocational rehabilitation services from the California Department of Rehabilitation, sought to have his rent covered while attending a law school outside commuting distance from his home. The Department agreed to cover his tuition and other expenses but refused to pay his rent, classifying it as a non-covered "long-term everyday living expense." Doe argued that rent should be considered "maintenance" under the Rehabilitation Act of 1973 and related California law, which the Department disputed.An administrative law judge (ALJ) upheld the Department's decision, interpreting the law to allow rent as "maintenance" only for short-term shelter, not for the three-year duration Doe required. The Superior Court of Orange County denied Doe's petition for a writ of mandate, agreeing with the ALJ that three years of rent did not qualify as "short-term shelter."The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court found that the term "maintenance" under the Rehabilitation Act and California law includes costs incurred in excess of normal expenses while receiving vocational rehabilitation services, without distinguishing between short-term and long-term costs. The court held that the Department's categorical refusal to cover long-term rent as "maintenance" was incorrect. The court reversed the lower court's decision and remanded the case, directing the Department to reconsider Doe's request for rental assistance based on his individual circumstances, rather than a blanket policy against long-term expenses. View "Doe v. Dept. of Rehabilitation" on Justia Law

Donna Ard applied for disability benefits, claiming she was disabled due to various health issues, including anemia, chronic pain, depression, PTSD, and OCD. She was 49 years old at the time of her application, six months and seventeen days shy of her 50th birthday. Ard's application was denied by the Social Security Administration, and she subsequently requested a hearing before an administrative law judge (ALJ). The ALJ also denied her application, finding that she was not disabled under the Social Security Act.Ard appealed the ALJ's decision to the Social Security Appeals Council, which denied her request for review. She then filed a complaint in the United States District Court for the District of South Carolina. The magistrate judge affirmed the ALJ's decision, holding that the ALJ was not required to consider whether Ard should be treated as a person closely approaching advanced age under the borderline age rule, as she was more than six months away from her 50th birthday.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the magistrate judge's decision. The court held that the borderline age rule, which allows for consideration of a higher age category if an applicant is within a few days to a few months of reaching that category, did not apply to Ard because she was more than six months away from turning 50. The court found that the ALJ had correctly applied the legal standards and that the factual findings were supported by substantial evidence. Therefore, the court concluded that the ALJ was not required to consider treating Ard as a person closely approaching advanced age. The decision of the district court was affirmed. View "Ard v. O'Malley" on Justia Law

James Morell, a retired research attorney for the Orange County Superior Court, was entitled to a pension under the County Employees Retirement Law of 1937 (CERL). The dispute arose over whether the $3,500 Optional Benefit Program (OBP) payments he received should be included in the calculation of his pension. The OBP allowed attorneys to allocate the $3,500 benefit to various options, including taxable cash or a healthcare reimbursement account. Morell allocated portions of the OBP to both cash and healthcare reimbursement in the years leading up to his retirement.The Superior Court of Los Angeles County initially ruled in favor of Morell, ordering the Board of Retirement for the Orange County Employees’ Retirement System (OCERS) to reconsider its decision excluding the OBP payments from Morell’s pension calculation. The court found that the board had improperly relied on a settlement agreement and a repealed statute, Government Code section 31460.1, which had excluded such payments from the definition of "compensation."The California Court of Appeal, Second Appellate District, reviewed the case. The court concluded that Resolution 90-1551, adopted by the Orange County Board of Supervisors, which excluded OBP payments from the definition of "compensation," remained valid despite the repeal of section 31460.1. The court found that Morell had elected to participate in the OBP by allocating the $3,500 benefit, and these payments reflected amounts that exceeded his salary. Therefore, the exclusion of the OBP payments from the pension calculation was proper.The Court of Appeal reversed the trial court’s judgment and remanded the case with directions to deny Morell’s petition. The court held that Resolution 90-1551 was still valid and that the OBP payments were correctly excluded from Morell’s pension calculation. View "Morell v. Board of Retirement for the Orange County Employees’ Retirement System" on Justia Law

Scott Carlberg was convicted by a jury of four counts of wire fraud for fraudulently obtaining disability benefits from the United States Railroad Retirement Board (RRB). Carlberg, who had suffered a traumatic brain injury while working at Soo Line Railroad, applied for occupational disability benefits in 2013 and later for enhanced benefits in 2015. The RRB requires applicants to disclose any non-railroad work and earnings, which Carlberg failed to do accurately. Despite purchasing and operating a tanning salon, Carlberg misrepresented his work activities to the RRB, leading to his prosecution.The United States District Court for the Northern District of Illinois denied Carlberg’s motion to set aside the jury’s verdict, which argued that the evidence did not show he intentionally participated in a scheme to defraud or made material misrepresentations. The court found sufficient evidence that Carlberg had concealed his ownership and involvement in the salon, and that his misrepresentations were material to the RRB’s decision to grant him benefits. Carlberg was sentenced to 30 months’ imprisonment and ordered to pay $279,655.22 in restitution, representing the full value of the benefits he received.The United States Court of Appeals for the Seventh Circuit reviewed Carlberg’s appeal, which challenged both the denial of his motion for acquittal and the restitution award. The court found that the evidence at trial was sufficient to support the jury’s verdict, as it showed Carlberg engaged in significant physical and mental duties at the salon, which would have disqualified him from receiving benefits. The court also upheld the restitution award, agreeing that the government had proven the full amount of benefits Carlberg received was ill-gotten. The Seventh Circuit affirmed the district court’s decisions. View "United States v. Carlberg" on Justia Law

Nancy Vargas, a bus driver for the Santa Barbara Metropolitan Transit District, injured her foot at work in March 2018. She settled her claim against the district in December 2020, with a stipulated permanent disability of 26 percent. Vargas applied for subsequent injury benefits from the Subsequent Injuries Benefits Trust Fund (Fund), listing pre-existing disabilities and disclosing that she was receiving Social Security Disability Insurance (SSDI) payments. The Fund acknowledged her eligibility but sought to reduce her benefits by the amount of her SSDI payments, claiming these were for her pre-existing disabilities.The Workers’ Compensation Appeals Board (Board) determined that the Fund was not entitled to this reduction, as the Fund had not proven that Vargas’s SSDI payments were awarded for her pre-existing disabilities. The Board found that the evidence provided, including an award letter from the Social Security Administration, did not specify the basis of the SSDI benefits. The Fund’s petition for reconsideration was denied by the Board, which maintained that the Fund needed to show the SSDI payments were for pre-existing disabilities to claim a reduction.The California Court of Appeal, Second Appellate District, reviewed the case. The court affirmed the Board’s decision, holding that the Fund bears the burden of proving its entitlement to a reduction in benefits under section 4753 of the Labor Code. The court found that the Fund did not provide sufficient evidence to establish that Vargas’s SSDI payments were for her pre-existing disabilities. The court emphasized that the Fund must meet its burden of proof by a preponderance of the evidence and that the stipulated disability rating in Vargas’s settlement with her employer did not automatically entitle the Fund to a reduction in benefits. The Board’s order denying the Fund’s petition for reconsideration was affirmed. View "Subsequent Injuries Benefits Trust Fund v. Workers Comp. App. Bd." on Justia Law

Joshua Jones applied for disability insurance benefits (DIB) and supplemental security income (SSI) on October 1, 2019, citing various medical conditions including disc herniation, diabetes, and high blood pressure. His applications were denied initially and upon reconsideration. Jones then requested a hearing before an administrative law judge (ALJ), which took place on August 5, 2021. The ALJ denied his claims on October 6, 2021. Jones appealed to the Appeals Council, which denied review. Subsequently, he sought judicial review in the United States District Court for the Eastern District of Louisiana, which upheld the Commissioner’s decision.The district court reviewed cross-motions for summary judgment and adopted the magistrate judge’s recommendation to deny Jones’ motion and grant the Commissioner’s motion. The court found that the ALJ had applied the correct legal standards and that substantial evidence supported the decision. Jones then appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit affirmed the district court’s judgment. The court held that the ALJ correctly applied Listing 1.15, which became effective on April 2, 2021, rather than the older Listing 1.04, to evaluate Jones’ claims. The court found that applying the new listing to pending claims did not constitute impermissible retroactivity. Additionally, the court determined that the ALJ’s decision was supported by substantial evidence, including the finding that Jones did not meet the criteria for medical equivalency under Listing 1.15. The court also concluded that the ALJ properly considered the impact of Jones’ medical treatments on his ability to maintain employment, finding no evidence that his treatment regimen significantly interrupted his ability to work. View "Jones v. O'Malley" on Justia Law

James Morell, a retired research attorney for the Orange County Superior Court, was entitled to a pension under the County Employees Retirement Law of 1937 (CERL). The dispute arose over whether the $3,500 Optional Benefit Program (OBP) payments he received should be included in the calculation of his pension. The OBP allowed attorneys to allocate the $3,500 to various benefits or receive it as taxable cash. Morell allocated portions to a healthcare reimbursement account and cash. The Orange County Employees’ Retirement System (OCERS) excluded these payments from his pension calculation, leading to prolonged litigation.The Los Angeles County Superior Court initially ruled in favor of Morell, ordering OCERS to reconsider its decision without relying on Resolution 90-1551, which OCERS argued required the exclusion of OBP payments. The court found that the resolution had been invalidated and that Morell could not waive his argument that OCERS’ calculation contravened CERL through a settlement agreement.The California Court of Appeal, Second Appellate District, Division One, reviewed the case. The court concluded that Resolution 90-1551, which adopted the provisions of the now-repealed Government Code section 31460.1, remained valid due to a savings clause in Senate Bill 193. This clause preserved actions taken by counties under section 31460.1 before its repeal. The court found that Morell had elected to participate in the OBP and that the payments reflected amounts exceeding his salary.The Court of Appeal reversed the trial court’s judgment and remanded the case with directions to deny Morell’s petition. The court held that Resolution 90-1551 was still valid and that OCERS correctly excluded the OBP payments from Morell’s pension calculation. View "Morell v. Board of Retirement of the Orange County Employees' Retirement System" on Justia Law

The case involves the Sandpiper Residents Association and other residents of Sandpiper Cove, a privately owned apartment complex in Texas, subsidized by the U.S. Department of Housing and Urban Development (HUD) under its Section 8 project-based rental assistance program. The residents sued HUD, alleging that the agency failed to ensure that Sandpiper Cove was maintained in a habitable condition. They sought to compel HUD to issue Tenant Protection Vouchers, which would allow them to receive rental payment assistance for use at other properties.The District Court dismissed the residents' claims for lack of subject-matter jurisdiction, reasoning that their claims had been mooted by the sale of Sandpiper Cove to a new owner who had not received a Notice of Default. The residents appealed this decision.The United States Court of Appeals for the District of Columbia Circuit held that the District Court erred in dismissing the residents' claims as moot. The court found that the question of whether the residents were legally entitled to relief after the sale of Sandpiper Cove went to the merits of their case, not mootness. However, the court affirmed the District Court’s dismissal of the residents' complaint because they failed to state a claim upon which relief could be granted. The court held that the residents had not shown that the new owner of Sandpiper Cove had received a Notice of Default, a condition necessary for the issuance of Tenant Protection Vouchers under the relevant statute. View "Sandpiper Residents Association v. Housing and Urban Development" on Justia Law