Justia Government & Administrative Law Opinion Summaries

Claimant sustained a work-related injury in 2003, for which he was awarded temporary total disability (TTD) benefits followed by 425 weeks of permanent partial disability benefits. In 2007 Claimant sustained another injury. After finding the effects of the 2003 injury caused Claimant's 2007 injury, an ALJ increased Claimant's partial disability benefit at reopening and tripled the entire income benefit awarded for his injury. The workers' compensation board and court of appeals affirmed. The Supreme Court affirmed, holding (1) substantial evidence supported the finding of increased impairment as well as the finding that Claimant lacked the physical capacity at reopening to perform the type of work performed at the time of his injury; and (2) the combined effects of the impairment present at the time of the initial award and the additional impairment present at reopening entitled Claimant to triple benefits based on the whole of his disability for the balance of the compensable period. View "James T. English Trucking v. Beeler" on Justia Law

This appeal concerned an ALJ's decision to award the claimant temporary total disability (TTD) benefits for his work-related shoulder injury from the date he left work, May 10, 2007, until May 8, 2009. The ALJ also awarded permanent income and medical benefits for the injury but denied claims for cervical and lumbar spine injuries. A court of appeals majority reversed, concluding that the opinion and award failed to contain findings adequate to make clear whether the ALJ considered and understood all of the evidence relevant to the date when TTD began. The Supreme Court (1) reversed to the extent that the ALJ made the finding of fact required by Kan. Rev. Stat. 342.0011(11)(a); but (2) affirmed to the extent the Court was unable to determine whether the ALJ simply misstated May 10, 2007 as being the date the claimant testified he stopped working due to the effects of his injury, misunderstood the evidence concerning his reason for missing work on May 10, 2007, or chose May 10, 2007 based on other evidence. Remanded to the ALJ to clarify that portion of the decision. View "Arnold v. Toyota Motor Mfg." on Justia Law

Strata Corporation and Liberty Mutual Fire Insurance Company appealed a partial summary judgment dismissing Liberty Mutual's subrogation claim against United Crane & Excavation, Inc., after the district court certified the partial summary judgment as final under N.D.R.Civ.P. 54(b). Because this case did not represent the "infrequent harsh case for immediate appeal and subsequent proceedings in the district court may moot the issue raised on appeal," the district court improvidently certified the partial summary judgment as final and the Supreme Court dismissed the appeal. View "City of Mandan v. Strata Corp." on Justia Law

James Mickelson appealed a judgment affirming a Workforce Safety and Insurance ("WSI") decision denying his claim for workers' compensation benefits. He argued WSI erred in deciding he did not suffer a compensable injury. Upon review, the Supreme Court concluded WSI misapplied the definition of a compensable injury, and the Court reversed and remanded for further proceedings. View "Mickelson v. Workforce Safety & Ins." on Justia Law

Perks applied for disability insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. An ALJ denied Perks's application. On appeal to the appeals council, Perks submitted additional evidence. The appeals council noted the receipt of the additional evidence but denied further review of Perks's claim. The district court affirmed. The Eighth Circuit Court of Appeals affirmed, holding (1) substantial evidence supported the ALJ's finding that Perks was not disabled; and (2) the additional evidence submitted to the appeals council did not undermine the ALJ's determination, as the ALJ would not have reached a different result with the additional evidence and the ALJ's decision was supported by substantial evidence in the record as a whole.

Kevin Byes applied for disability insurance benefits and supplemental security income on July 30, 2007, claiming disability since November 1, 2005. The Commissioner of Social Security Administration (Commissioner) denied benefits. An administrative law judge (ALJ) upheld the Commissioner's decision, concluding that Byes was not disabled from November 1, 2005 through the date of the decision. The district court agreed with the ALJ's decision. The Eighth Circuit Court of Appeals affirmed, holding that substantial evidence supported the ALJ's finding of no severe mental impairment; and (2) the district court correctly concluded that the ALJ had applied the incorrect grid rule in order to determine Byes was not disabled but that the error was harmless.

Aetna Life Insurance Company, as the plan administrator, determined Sharon Wade was no longer disabled and stopped paying long-term disability benefits from Wade's former employer's welfare benefit plan. Wade sought judicial review of Aetna's decision by filing a civil action under ERISA. The district court granted summary judgment in favor of Aetna, concluding that Aetna did not abuse its discretion in terminating Wade's benefits because substantial evidence supported the decision. The Eighth Circuit Court of Appeals affirmed, holding that the district court (1) applied the appropriate standard of review; (2) gave appropriate weight to the Social Security Administration's grant of long-term disability benefits to Wade; and (3) did not abuse its discretion by determining substantial evidence supported Aetna's termination of benefits.

A healthcare worker was sprayed in the eye with fluids from an HIV-positive patient. She received preventive treatment and counseling. Her employer initially paid workers' compensation benefits; it later filed a controversion based on its doctor's opinion that the employee was able to return to work. The employee asked for more benefits, but the Alaska Workers' Compensation Board denied her claim. The employee appealed, but the Alaska Workers' Compensation Appeals Commission affirmed the Board's decision. Because the Supreme Court agreed with the Commission that substantial evidence supported the Board's decision, the Court affirmed the Commission's decision.

Employee-Respondent Aletha Johnson hurt her back while working for Employer-Appellant Rent-A-Center, Inc. The company contended that the appellate panel of the Workers' Compensation Commission erred by awarding Respondent workers' compensation benefits. The appellate panel found Respondent was disabled and did not constructively refuse light duty work. The Supreme Court found that Respondent qualified as disabled under section 42-1-120 of the South Carolina Code, and affirmed the appellate panel's decision to award benefits.

In 2008, Craig Ali was a police officer for appellant, the village of Oakwood. That spring, his department assigned him to perform traffic-control duties on a highway-construction project overseen by appellee, Kokosing Construction Company, Inc. Ali was injured while performing those duties. At issue was which entity was Ali's employer for purposes of his workers' compensation claim. A district hearing officer with the Industrial Commission of Ohio found that Kokosing was Ali's employer at the time of injury. A staff hearing officer reversed, finding the correct employer was Oakwood Village. The Supreme Court affirmed, holding (1) the commission, when confronted with two potential employers, may, but is not required to, use any of the State ex rel. Lord v. Daugherty and Fisher v. Mayfield factors it believes will assist analysis; (2) therefore, the commission did not abuse its discretion by not directly discussing the three enumerated Lord/Fisher factors; and (3) the staff hearing officer's decision was supported by evidence in the record.