Justia Government & Administrative Law Opinion Summaries

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

Catherine Bradford applied for Social Security disability insurance benefits and supplemental security income, claiming she became unable to work due to multiple ailments. Her disability insurance coverage expired on September 30, 2018, and to receive benefits, she had to establish that her period of disability began between April 24, 2015, and September 30, 2018. Bradford also sought supplemental security income payments for the period between April 24, 2015, and April 8, 2020. Bradford's medical records included opinions from a nurse practitioner, three state-agency physicians, and a family medicine practitioner.The administrative law judge (ALJ) determined that Bradford had not performed substantial gainful activity since the date of her alleged disability and that she was severely impaired by multiple ailments. However, the ALJ found that none of these impairments, either individually or in combination, met or medically equaled the severity of any impairment listed in the relevant regulation. The ALJ assessed Bradford’s residual functional capacity before April 9, 2020, and concluded that she was capable of performing light work, subject to certain limitations. The ALJ determined that Bradford’s limitations did not preclude her from performing her past work as a housekeeper, laundry aide, or factory cleaner. The ALJ gave Nurse Ash’s opinion little weight and gave great weight to the opinions of the state-agency physicians and Dr. Keown.The Appeals Council denied review, and the district court granted judgment for the Commissioner. Bradford appealed, arguing that the ALJ committed legal error by disregarding a prior remand order of the district court and disputing the ALJ’s conclusion that she could perform light work. The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision, concluding that the ALJ permissibly weighed the evidence and committed no legal error. The court found that the ALJ's determination that Bradford could stand for six hours and perform light work was supported by substantial evidence. View "Bradford v. Kijakazi" on Justia Law

The case involves Melissa Palmer, who applied for Pandemic Unemployment Assistance (PUA) benefits due to loss of income from her self-employment as a sign-language interpreter during the COVID-19 pandemic. Despite continuing to work her second job at Woofs and Waves, she did not report this income in her weekly requests for benefits. The South Dakota Department of Labor and Regulation, Reemployment Assistance Division (Department) determined that she had misrepresented her income and was therefore ineligible for the benefits she had received. The Department ordered her to repay the benefits and assessed a mandatory penalty.The administrative law judge (ALJ) upheld the Department's decision, finding that Palmer had willfully misrepresented her income. The circuit court affirmed the ALJ’s decision. Palmer appealed, arguing that she had not willfully misrepresented her income because she believed she only needed to report her self-employment income.The Supreme Court of the State of South Dakota reversed the lower courts' decisions. The Court found that the ALJ's finding that Palmer believed she only needed to report her self-employment income was inconsistent with the conclusion that she had willfully misrepresented her income. The Court held that a willful misrepresentation requires evidence of intentional misrepresentation, not merely knowledge of the falsity of the representation. The Court remanded the case for the ALJ to reconsider whether Palmer was at fault for the overpayment and whether she was eligible for a waiver. View "Palmer V. Dep’t Of Labor & Regulation" on Justia Law

The case involves Dennis G. Crosen, a former employee of Blouin Motors, Inc., who suffered two work-related injuries in 1984 and 2002, respectively. The 1984 injury occurred while Crosen was working for Rockingham Electric, Inc., and the 2002 injury occurred while he was working for Blouin Motors, Inc. The two injuries combined to render Crosen totally incapacitated. A hearing officer apportioned 40% of the responsibility for Crosen's incapacity to Rockingham and 60% to Blouin. In 2014, Crosen began collecting old-age insurance benefits under the United States Social Security Act. By statute, Blouin's obligation to pay weekly incapacity benefits based on the 2002 injury was to be reduced by half of the amount of Social Security benefits that Crosen receives. No Social Security offset applies to the compensation that Rockingham owes for the 1984 injury.The Administrative Law Judge (ALJ) and the Workers’ Compensation Board Appellate Division denied Blouin's petition to apply the entire Social Security offset to its compensation payments to Crosen. The ALJ and the Appellate Division interpreted the relevant statute to mean that Blouin could only apply the offset to the portion of the benefits for which it was responsible (60%), not the entire amount.The Maine Supreme Judicial Court disagreed with the lower courts' interpretation of the statute. The court held that Blouin was entitled to take the full offset provided by the statute, not just the portion corresponding to its share of responsibility for Crosen's incapacity. The court vacated the decision of the Appellate Division and remanded the case for further proceedings. The court also noted that Blouin may be entitled to a credit for the portion of the offset that it did not take prior to this case, but left this issue to be resolved on remand. View "Crosen v. Blouin Motors., Inc." on Justia Law

The case revolves around a group of Texans who were receiving Pandemic Unemployment Assistance (PUA) until the Texas governor informed the Department of Labor that Texas would withdraw from its agreement with the Secretary of Labor to participate in the PUA program. The plaintiffs argued that the Federal Government violated the mandate in PUA that the Secretary of Labor “shall provide . . . assistance” to “any covered individual.”The United States District Court for the Western District of Texas dismissed the case, agreeing with the magistrate judge's recommendation. The judge reasoned that the CARES Act, which established the PUA, required the existence of an agreement with a state for the payment of benefits. The judge also noted that the Act did not provide a mechanism for the Secretary to pay out benefits in the absence of an agreement with the relevant state. The judge concluded that Congress intended for the funds to be administered solely by the states.The plaintiffs appealed to the United States Court of Appeals for the Federal Circuit. The court affirmed the lower court's decision, stating that the PUA does not require the Secretary to pay PUA benefits to individual citizens; rather, the Secretary must provide assistance through agreements with the states. The court concluded that the plaintiffs failed to state a claim under the Little Tucker Act. View "CREAGER IRELAND v. US " on Justia Law

The case involves Keeley Hamilton, who applied for disability insurance benefits and supplemental security income from the Social Security Administration (SSA) due to her physical impairments. An administrative law judge (ALJ) within the SSA denied her applications, concluding that despite her physical impairments, she could still work in two occupations. Hamilton appealed, arguing that she should be considered disabled unless she could work in at least three occupations, a rule she derived from Ninth Circuit caselaw.Hamilton's applications were initially denied by an ALJ, who found that she could still work in two occupations despite her physical impairments. The district court remanded the case back to the SSA for further proceedings, citing a failure to ask the vocational expert about potential conflicts between his testimony and the occupational information in the Dictionary of Occupational Titles. On remand, the ALJ held another hearing and again denied Hamilton's applications, concluding that Hamilton's skills permitted her to perform two semi-skilled sedentary occupations: food checker and auction clerk.In the United States Court of Appeals for the Sixth Circuit, Hamilton argued that the ALJ should have found her disabled because his findings showed that her skills did not transfer to at least three occupations. The court disagreed with Hamilton's interpretation of the rule, stating that the ALJ did not err by ruling that Hamilton was not disabled under the regulations because she had skills that transferred to a significant range of work. The court affirmed the district court's decision upholding the Social Security Administration's denial of benefits to Hamilton. View "Hamilton v. Comm'r of Soc. Sec." on Justia Law

Lonnie Reidburn, a self-employed insurance agent, appealed a decision by the South Dakota Department of Labor, Reemployment Assistance Division (Department) that he must repay $24,690 in pandemic unemployment benefits he received. Reidburn's income was based on commissions he received for new policies and renewals, which required in-person visits to clients' homes or businesses. During the COVID-19 pandemic, Reidburn experienced a significant reduction in his ability to procure new policies and renewals because clients did not want him to make in-person visits. As a result, Reidburn's income decreased. He applied for Pandemic Unemployment Assistance (PUA) through the Department and received benefits for 39 weeks. However, the Department later determined that Reidburn's loss of income was not the direct result of the pandemic and issued a determination of ineligibility.The administrative law judge (ALJ) upheld the Department's determination of ineligibility, reasoning that the individual decisions of Reidburn's clients to preclude him from entering their homes or places of business were not a direct result of the pandemic. However, the ALJ rejected the Department's at-fault determination and found that Reidburn was not at fault for the overpayment. The ALJ also concluded that Reidburn's request for a waiver was untimely. Reidburn appealed the ALJ's decision to the circuit court, which affirmed the ALJ's decision.The Supreme Court of the State of South Dakota reversed the ALJ's determination that Reidburn was ineligible to receive PUA benefits for 35 of the 39 weeks at issue, based on its recent decision in Bracken v. South Dakota Department of Labor and Regulation, Reemployment Assistance Division. The court declined to address the Department's argument that Reidburn failed to present sufficient evidence to support his testimony that he experienced a significant reduction in services, as the Department did not raise this argument at Reidburn's administrative hearing. The court affirmed the circuit court's denial of Reidburn's motion for attorney fees. View "Reidburn v. Department of Labor & Regulation" on Justia Law

The case revolves around Brenda Warnell, who applied for disability insurance benefits and supplemental security income under the Social Security Act in 2019. Warnell claimed she was unable to work due to debilitating migraines and chronic pain in her back, shoulders, and neck. Her medical record was mixed, with some physicians assessing her as having severely limited functional capacity, while others found her capable of limited physical exertion.The Administrative Law Judge (ALJ) denied Warnell's claim, finding that the medical evidence did not substantiate the severity of her alleged functional limitations. The ALJ concluded that Warnell's pain symptoms did not prevent her from performing light work with moderate noise and limited physical requirements. The ALJ's decision was affirmed by the district court.In the United States Court of Appeals for the Seventh Circuit, Warnell challenged the ALJ's decision, arguing that the ALJ needed to provide more detailed accounts of the medical evidence. The court rejected this argument, stating that the ALJ's decision was supported by substantial evidence and met the light standard set by the Supreme Court. The court found that the ALJ had provided a sufficient explanation for her decision, highlighting specific evidence that contradicted Warnell's claims and addressing conflicting evidence. The court affirmed the ALJ's decision, rejecting Warnell's claim that the ALJ needed to provide more detailed accounts of the medical evidence. View "Warnell v. O'Malley" on Justia Law