Justia Public Benefits Opinion Summaries

The Supreme Court affirmed the decision of the district court entering summary judgment for the United States and rejecting the lawsuit brought by Appellant asking the district court to overturn the finding of the Food and Nutrition Service (FNS) of the United States Department of Agriculture that Appellant was disqualified from further participation in the supplemental nutrition assistance program (SNAP), holding that there was no error.FNS disqualified Appellant from further participation in SNAP after investigating evidence of unlawful trafficking in SNAP benefits. Thereafter, Appellant brought this action seeking to overturn the FNS's liability finding and asking the court to vacate the order of program disqualification as arbitrary and capricious. The district court entered summary judgment for the United States. The Supreme Court affirmed, holding (1) the district court did not err in entering summary judgment in favor of the United States on the liability issue; and (2) the sanction of the permanent disqualification order from the program was neither arbitrary nor capricious. View "AJ Mini Market, Inc. v. United States" on Justia Law

Plaintiff filed in the U.S. District Court for the Western District of Washington a pro se action to challenge the denial of his claim for disability benefits by the Social Security Administration. A magistrate judge of that court, acting with the full civil authority of that court, reversed and remanded the matter to the agency for rehearing after the government conceded that there was an error in the agency’s adjudication. Plaintiff appealed that decision.   The Ninth Circuit affirmed. The panel considered whether the magistrate judge had authority to exercise the full civil jurisdiction of the district court over Plaintiff’s claim. There is no doubt that the district court had jurisdiction over the case, but Plaintiff challenged whether he had given the consent that was required for a magistrate judge to exercise that jurisdiction. The panel held that it had jurisdiction to review the antecedent question of whether the magistrate judge validly entered judgment on behalf of the district court. The panel rejected Plaintiff’s contention that, as a pro se litigant, he believed he was consenting to the magistrate judge’s issuance of a report and recommendation, not a final judgment. The panel held that Plaintiff was fully informed of the district court’s conclusion that he had knowingly and voluntarily consented to the assignment to the magistrate judge. Further, the court wrote that Plaintiff was unable to show good cause or extraordinary circumstances to withdraw consent. The panel affirmed the district court’s conclusion that Plaintiff consented to magistrate judge jurisdiction. View "VICTOR WASHINGTON V. KILOLO KIJAKAZI" on Justia Law

Martinez applied for supplemental security income. An ALJ reviewed the record and found that Martinez suffered from severe impairments but could nonetheless “perform the requirements of representative unskilled occupations such as a checker, routing clerk, and mail sorter.” After the Appeals Council denied Martinez’s request to review the decision, Martinez filed suit, then notified the Commissioner that the administrative record (pages within exhibit B15F) included medical records regarding a different claimant. In filing the administrative record with the court, the Commissioner noted that it was the full record. The pages relating to the other claimant were removed and replaced with a placeholder reading: “THIS PAGE WAS REMOVED AS AN EXHIBIT BY THE APPEALS COUNCIL BECAUSE IT DOES NOT REFER TO THE CLAIMANT.” Neither Martinez nor the district court saw the omitted pages. The Commissioner refused to produce the pages. Martinez moved to compel the Commissioner to include the full exhibit in the administrative record. The district court denied that motion, stating that “[t]he ALJ [only] cited the third-party records in exhibit B15F … as additional potential evidence that Mr. Martinez had an impairment.” The district court then affirmed the denial as supported by substantial evidence.The Seventh Circuit reversed. The decision is not supported by substantial evidence because it relies on medical records belonging to someone other than Martinez; it is impossible to determine whether that error was harmless. View "Martinez v. Kijakazi" on Justia Law

The VA’s Schedule for Rating Disabilities includes diagnostic codes (DCs), each with a corresponding disability rating, 38 U.S.C. 1155. A particular veteran’s disability may not clearly fall under a delineated DC. VA regulations provide: When an unlisted condition is encountered it will be permissible to rate under a closely related disease or injury in which not only the functions affected but the anatomical localization and symptomatology are closely analogous. The VA considers the functions affected by ailments, the anatomical localization of the ailments, and the symptomatology of the ailments.Webb served in the Army, from 1968-1970, receiving an honorable discharge. Webb later developed service-connected prostate cancer, the treatment for which caused him to develop erectile dysfunction (ED). In 2015, Webb was assigned a non-compensable (zero percent) rating for his ED. The Schedule did not then include a diagnostic code for ED. The VA rated Webb’s disability by analogy to DC 7522, which provides a 20 percent disability rating for “[p]enis, deformity, with loss of erectile power.” The Board explained that DC 7522 required Webb to show “deformity of the penis with loss of erectile power.” Without such a deformity, he was not entitled to a compensable disability rating. The Veterans Court affirmed. The Federal Circuit vacated. The listed disease or injury to which a veteran’s unlisted condition is being rated by analogy must be only “closely related,” not identical. View "Webb v. McDonough" on Justia Law

Hohman, age 53, applied for Social Security benefits after she stopped working. She suffers from fibromyalgia, PTSD, depression, and anxiety, and alleged that the combined effects of these conditions left her unable to work as a medical records clerk or patient access representative. A vocational expert testified that someone with Hohman’s limitations could work as a photocopy machine operator, small products assembler, or mail clerk. Relying on that testimony, an ALJ denied the claim for benefits, finding that despite her limitations, Hohman still had the capacity to perform light work with physical and social limitations available in significant numbers in today’s economy. The vocational expert stated that he arrived at his final numbers about jobs available in the economy through a “weighted estimate" based upon professional experience, 25 years of both placement and labor market survey work, and 2,000 labor market surveys, explaining that many of the job titles in the database had been merged or had been eliminated by technology, so he decided that the job titles should not receive equal weight.The Seventh Circuit and the district court affirmed. Substantial evidence supports the denial. The court acknowledged Hohman’s frustration with the equal distribution method and concerns about the method’s reliability but stated that it is not, by itself, reversible error for an ALJ to rely on the equal distribution method to make a job-number determination. View "Hohman v. Kijakazi" on Justia Law

Leisgang suffers from depression, anxiety, and a personality disorder, among other conditions. He sought supplemental security income and disability insurance benefits. The ALJ concluded that Leisgang could undertake only simple, routine, and repetitive work; could not work at a rapid, production-rate pace; could tolerate few changes in routine work settings; and could interact only occasionally with supervisors, coworkers, and the public. Those limitations precluded Leisgang from performing his past work. To determine whether Leisgang could perform other available jobs, the ALJ sought assistance from a vocational expert, who testified that someone with Leisgang’s limitations could work as a kitchen helper, sweeper/cleaner, or hospital cleaner. The expert estimated that there were meaningful numbers of each job across the country, identifying job titles using the Department of Labor's 1977 dictionary, not revised since 1991. The primary data came from the Occupational Employment Quarterly, which applies the equal distribution method to estimate the distribution of job numbers within a larger group of occupations. When Leisgang asked if that method was reliable, the expert reported that it was the only method he had available. Leisgang asked no further questions about the methodology.The district court and Seventh Circuit affirmed the denial of benefits. Leisgang forfeited his argument that the ALJ should have done more to ensure the soundness of the vocational expert’s methodology by failing to object at the hearing. Substantial evidence otherwise supports the ALJ’s determination. View "Leisgang v. Kijakazi" on Justia Law

Out-of-work residents of Michigan may claim unemployment benefits if they meet certain eligibility criteria. The State’s Unemployment Insurance Agency oversees the benefits system. In 2011, with the help of private contractors, the Agency began to develop software to administer the unemployment system. The Agency sought to equip the software to auto-adjudicate as many parts of the claims process as possible. The Agency programmed software that used logic trees to help process cases and identify fraud. A claimant’s failure to return the fact-finding questionnaire, for example, led to a fraud finding, as did the claimant’s selection of certain multiple-choice responses. In August 2015, problems arose with some features of the system, prompting the Agency to turn off the auto-adjudication feature for fraud claims.Plaintiffs are four individuals who obtained unemployment benefits, which were terminated after the Agency flagged their claims for fraud. Plaintiffs filed a putative class action against three government contractors and nineteen Agency staffers, raising claims under the Fourth, Fifth, and Fourteenth Amendments, 26 U.S.C. Sec. 6402(f), and Michigan tort law. In a previous proceeding, the court held that plaintiffs’ due process rights clearly existed because they had alleged a deprivation of their property interests without adequate notice and without an opportunity for a pre-deprivation hearing.At this stage, because the remaining plaintiffs have failed to show that these procedures violate any clearly established law, the supervisors of the unemployment insurance agency are entitled to judgment as a matter of law. The court also found that an intervening plaintiff was properly prevented from joining the case, based on her untimely filing. View "Patti Cahoo v. SAS Institute, Inc." on Justia Law

Claimant appealed the district court’s judgment upholding the denial of social security benefits by an administrative law judge (“ALJ”). Reviewing de novo the district court’s decision, Farlow v. Kijakazi, 53 F.4th 485, 487 (9th Cir. 2022), the Ninth Circuit reversed The ALJ materially mischaracterized Claimant’s functional capacity when posing a question to a vocational expert, so the vocational expert’s testimony lacked evidentiary value with respect to jobs that Claimant could perform. Here, Claimant argued that the ALJ’s question posed to the vocational expert inaccurately described her actual limitations. First, the hypothetical posed to the expert did not provide that claimant was limited to jobs with “little or no judgment.” The panel concluded that the error was harmless because the vocational expert identified only jobs with that limitation. Second, the hypothetical did not provide that Claimant could “follow short, simple instructions” only. Third, in the question posed to the vocational expert, the ALJ described a hypothetical person who “can work in an environment with occasional changes to the work setting.” The panel concluded that the ALJ materially mischaracterized Claimant’s functional capacity when posing a question to a vocational expert, so the vocational expert’s testimony lacked evidentiary value with respect to jobs that Claimant could perform. View "CAROLINE LEACH V. KILOLO KIJAKAZI" on Justia Law

Plaintiff sought disability benefits from the Social Security Administration in 2018. He primarily based his application on pain in his lower back, hips, legs, knees, and feet, as well as on hypertension. Throughout the administrative process and upon review in federal district court, Plaintiff was denied benefits. He appealed.   The Fourth Circuit reversed and remanded the district court’s ruling affirming the ALJ’s final decision denying Plaintiff’s application for disability benefits. The court explained that nothing in the record expressly reconciles the differing mobility conclusions between 2018 and 2019, but it seems reasonable to believe that perhaps Plaintiff’s objective ailments worsened during that time, thereby impacting his mobility. To be sure, neither this Court nor an ALJ may infer a medical diagnosis—like symptom progression. But when insufficient evidence prevents an ALJ from soundly determining whether providers’ opinions are consistent, a Section 404.1520b(b)(2) inquiry by the ALJ could remedy the uncertainty with relative ease. Second, the court held that the ALJ improperly considered Plaintiff’s subjective complaints. Third, the court found that the ALJ improperly considered whether Plaintiff’s daily activities were inconsistent with his claim of disability. View "Renard Oakes v. Kilolo Kijakazi" on Justia Law

Hampton served in the Navy from 1985-1989. In 1997, she filed a claim for VA disability compensation for migraines. In 1998, the regional office (RO) increased Hampton’s rating to 30 percent, effective from 1997. In 1999, Hampton applied for a total disability rating based on individual unemployability (TDIU) effective from 1997 due to “migraine[s], bladder, [and] reflux.” The RO denied TDIU. Hampton never filed a notice of disagreement but filed a new claim for increased compensation based on migraines. This claim was denied in 1999; Hampton filed a notice of disagreement. In 2000, the Board affirmed the RO. In 2003, Hampton filed a new claim for increased compensation and a second TDIU application. The Board ultimately granted Hampton TDIU, effective from 2003. Hampton argued that her 1999 TDIU claim was still pending because she submitted additional evidence within the one-year appeal window but never received a determination. The Board denied entitlement to an earlier effective date, finding that the 1999 TDIU claim was not still pending when Hampton filed her 2003 claims.The Veterans Court and Federal Circuit affirmed; 38 CFR 3.156(b) does not require the VA to explicitly state whether submitted evidence is new and material to a claim, where that claim is implicitly denied after consideration of the evidence. The Board’s 2020 decision, by finding the 2000 decision an implicit denial of TDIU, was not making a new and material evidence determination in the first instance. The RO did so in 1999. View "Hampton v. McDonough" on Justia Law