Justia Public Benefits Opinion Summaries

Raymond, a veteran of the U.S. Air Force, was born in 1947 and was a long-term resident of Middlesboro, Kentucky. He worked in the coal-mining industry for over 20 years and developed severe respiratory issues. Raymond, a non-smoker, sought benefits under the Black Lung Benefits Act, 30 U.S.C. 901, but died while his claim was pending. Raymond’s claim was consolidated with a claim for survivor’s benefits submitted by his widow, Joanna. The ALJ awarded benefits to Joanna, on both Raymond’s behalf, and as his surviving spouse. The Benefits Review Board affirmed. Zurich, the insurer of Straight Creek Coal, sought review. The Sixth Circuit denied Zurich’s petition, upholding the ALJ’s conclusions that Zurich failed to rebut the presumption of timeliness, that Raymond had worked for at least 15 years in qualifying employment, and that Raymond had a total respiratory disability. Raymond worked only in surface mines or coal-preparation plants during his career; the ALJ properly relied on 20 C.F.R. 718.305(b)(2) and determined whether Raymond’s mining employment was “substantially similar” to underground mining. View "Zurich American Insurance Group v. Duncan" on Justia Law

Burris’s father served on active duty in Vietnam, 1969-1971, and was granted a permanent and total disability rating for schizophrenia effective 2000. Because of his father’s disability, Burris was eligible to receive Dependents’ Educational Assistance (DEA) benefits. In October 2010, Burris, then 35-years old, elected to receive retroactive benefits for a period 2002-2010. During a portion of that period, Burris was enrolled as an undergraduate student. Burris’s studies were interrupted in 2005 when his mother unexpectedly passed away. Burris became the primary caretaker for his father, who suffered from prostate cancer. Burris was unable to attend school until his DEA eligibility had expired. The VA denied Burris’s request for an extension of his eligibility period, citing VA regulations that prohibit extensions for dependents “beyond age 31,” 38 C.F.R. 21.3041(g)(1), (g)(2), 21.3043(b), and refused to reimburse Burris for educational expenses incurred 2002-2004 because DEA benefits cannot be paid for expenses incurred more than one year prior to the application date. The Board of Veterans’ Appeals and Veterans Court affirmed the denial of equitable relief. The Federal Circuit affirmed. The Veterans Court lacks jurisdiction to grant equitable relief in these circumstances, 38 U.S.C. 7261. View "Burris v. Wilkie" on Justia Law

The Eighth Circuit affirmed the Commissioner's denial of disability benefits and dismissal of plaintiff's complaint under 42 U.S.C. 405(g). The court held that the record overwhelmingly supported the determination that plaintiff was not disabled, and the court found no legal error in the ALJ's analysis. In this case, plaintiff was a stay-at-home father married to a physician; he cared for and transported his four young children, performed housekeeping tasks, managed the sale of the family's house, and negotiated with the builders of a new house; and the record demonstrated that not only did he participate in these varied activities, but that he was able to navigate the obvious stresses inherent in these activities when compliant with his prescribed medications. The court held that the ALJ's statements in the step-two and three analyses was not inconsistent with the ALJ's step-four Residual Functional Capacity determination. View "Chismarich v. Berryhill" on Justia Law

The Eighth Circuit affirmed the Commissioner's denial of disability benefits and dismissal of plaintiff's complaint under 42 U.S.C. 405(g). The court held that the record overwhelmingly supported the determination that plaintiff was not disabled, and the court found no legal error in the ALJ's analysis. In this case, plaintiff was a stay-at-home father married to a physician; he cared for and transported his four young children, performed housekeeping tasks, managed the sale of the family's house, and negotiated with the builders of a new house; and the record demonstrated that not only did he participate in these varied activities, but that he was able to navigate the obvious stresses inherent in these activities when compliant with his prescribed medications. The court held that the ALJ's statements in the step-two and three analyses was not inconsistent with the ALJ's step-four Residual Functional Capacity determination. View "Chismarich v. Berryhill" on Justia Law

The Fourth Circuit vacated the Social Security Administration's denial of plaintiff's application for disability insurance benefits. The court held that the ALJ erred by not according adequate weight to a prior disability determination by the North Carolina Department of Health and Human Services. Accordingly, the court remanded the case with instructions to vacate the denial of benefits and remanded for further administrative proceedings. View "Woods v. Berryhill" on Justia Law

The Fourth Circuit vacated the Social Security Administration's denial of plaintiff's application for disability insurance benefits. The court held that the ALJ erred by not according adequate weight to a prior disability determination by the North Carolina Department of Health and Human Services. Accordingly, the court remanded the case with instructions to vacate the denial of benefits and remanded for further administrative proceedings. View "Woods v. Berryhill" on Justia Law

Stephens was born in 1957 and has a ninth-grade education. He worked as a taxi dispatcher and a security guard in the 15 years preceding his alleged disability. Stephens contends that he is disabled by diabetes, kidney disease, knee and back pain, heart disease, high blood pressure, asthma, arthritis, and obesity. He was denied Supplemental Security Income (SSI) benefits. On remand, a different ALJ determined that Stephens’ impairments, although severe, were not disabling and that he could perform relevant past work. The district court and Seventh Circuit upheld the denial, rejecting arguments that the ALJ erred by improperly evaluating Stephens’s obesity (no longer a stand-alone disability) when determining the aggregate impact of his impairments; that the ALJ’s finding that the record lacked medical opinion evidence as to Stephens’ hypersomnolence or excessive sleepiness; and that the ALJ failed to incorporate all of his impairments and consider their combined impact to evaluate his residual functional capacity. View "Stephens v. Berryhill" on Justia Law

Stephens was born in 1957 and has a ninth-grade education. He worked as a taxi dispatcher and a security guard in the 15 years preceding his alleged disability. Stephens contends that he is disabled by diabetes, kidney disease, knee and back pain, heart disease, high blood pressure, asthma, arthritis, and obesity. He was denied Supplemental Security Income (SSI) benefits. On remand, a different ALJ determined that Stephens’ impairments, although severe, were not disabling and that he could perform relevant past work. The district court and Seventh Circuit upheld the denial, rejecting arguments that the ALJ erred by improperly evaluating Stephens’s obesity (no longer a stand-alone disability) when determining the aggregate impact of his impairments; that the ALJ’s finding that the record lacked medical opinion evidence as to Stephens’ hypersomnolence or excessive sleepiness; and that the ALJ failed to incorporate all of his impairments and consider their combined impact to evaluate his residual functional capacity. View "Stephens v. Berryhill" on Justia Law

Twelve Medicaid-participating hospitals (“Hospitals”) challenged the Department of Medicaid’s (“DOM’s”) recalculation of their Medicaid outpatient rates for fiscal year 2001. The chancery court affirmed the opinion of the DOM, finding that “DOM interpreted its own regulation – the State Plan, which is its contract with the federal government and which it is required to follow to receive federal funds to require Medicaid to calculate the cost to charge ratio by using Medicare Methodology, which at that time was using a blended rate.” The Mississippi Supreme Court found the plain language of Attachment 4.19-B of the State Plan provided a cost-to-charge-ratio formula for calculating outpatient rates. Laboratory and radiology charges were to be excluded from this formula, because they were reimbursed on a fee-for-service basis. DOM’s inclusion of radiology and laboratory services in the charges and substitution of costs with Medicare blended payment amounts was a clear violation of the State Plan. Therefore, the Court reversed the judgments of DOM and the chancery court. Consistent with its opinion, the Court remanded and ordered the Executive Director of DOM to recalculate the Hospitals’ cost-to-charge ratio using the Hospital’s submitted costs in their cost reports, excluding laboratory and radiology services, and reimbursing the Hospitals the appropriate amounts determined by using the State Plan. View "Crossgates River Oaks Hospital v. Mississippi Division of Medicaid" on Justia Law

The Supreme Court affirmed the district court’s grant of summary judgment in favor of Defendants, holding that Plaintiffs' claims were either moot or failed to state a claim as a matter of law.The hospital at which an injured child received medical care sought to secure payment for that care by asserting liens against the child’s interest in the tort claim against the driver of the car that struck the child. The child and his mother brought claims against the hospital owner and its payments vendor, arguing that the liens violated Medicaid law. When the liens were released, the district court granted summary judgment in favor of Defendants. The Supreme Court affirmed on the principles of mootness and Plaintiffs’ failure to state a claim as a matter of law. View "Shaffer v. IHC Health Services, Inc." on Justia Law