Justia Government & Administrative Law Opinion Summaries

A former underground coal miner developed severe respiratory problems, including chronic cough and significant limitations in daily activities, following nearly 12 years of employment in West Virginia coal mines. After his symptoms worsened post-employment, he filed a claim for benefits under the Black Lung Benefits Act in 2020. Medical testing revealed persistent lung function impairment, and four pulmonary specialists—two for the miner and two for his former employer—offered differing opinions on the cause of his disability. The miner’s experts attributed his impairment to legal pneumoconiosis resulting from coal mine dust exposure, while the company’s experts diagnosed asthma unrelated to mining.A United States Department of Labor administrative law judge (ALJ) heard the case. The parties stipulated to the miner’s work history, and the company was named the responsible operator. The ALJ found the miner’s experts’ opinions more persuasive, particularly because they addressed the regulatory definitions and considered the possibility that coal dust exposure worsened his condition. The ALJ concluded the miner had legal pneumoconiosis arising from his coal mine employment, was totally disabled, and that pneumoconiosis substantially contributed to his disability. The company’s experts were found less persuasive for not adequately addressing the regulatory definition or the potential contribution of coal dust. The Benefits Review Board (BRB) affirmed the ALJ’s decision, concluding that substantial evidence supported all findings.The United States Court of Appeals for the Fourth Circuit reviewed the company’s petition. The court held that the ALJ and BRB did not err in their factual findings or legal analysis. It found sufficient evidence that the miner had legal pneumoconiosis caused by coal mine employment and that the disease substantially contributed to his total disability. The Fourth Circuit denied the petition for review, affirming the award of black lung benefits to the miner. View "Central Appalachian Coal Company v. DOWCP" on Justia Law

Three individuals residing in Missouri, each of whom had significant difficulties applying for or recertifying their eligibility for SNAP benefits due to problems with the Missouri Department of Social Services (DSS) call center and application procedures, brought a lawsuit. They alleged wrongful denial of benefits and failure to provide reasonable accommodations for disabilities. All three eventually received SNAP benefits after joining the lawsuit but expected to need continued assistance. Empower Missouri, a nonprofit organization, also joined the suit, asserting that DSS’s practices forced it to divert resources to address these systemic problems.In the United States District Court for the Western District of Missouri, the plaintiffs claimed violations of specific provisions of the SNAP Act, the Due Process Clause of the Fourteenth Amendment, and the Americans with Disabilities Act (ADA), seeking declaratory and injunctive relief. The district court found that all plaintiffs had standing, rejected arguments that their claims were moot, and determined that DSS’s practices violated their due process and ADA rights. The court granted summary judgment in favor of the plaintiffs and issued a broad remedial order requiring systemic changes to DSS’s SNAP administration, including detailed operational requirements and ongoing reporting.On appeal, the United States Court of Appeals for the Eighth Circuit held that the individual plaintiffs had standing for their due process and ADA claims, but Empower Missouri did not, as its advocacy expenditures alone did not confer standing. The court determined that the SNAP Act provisions cited did not create individual rights enforceable under 42 U.S.C. § 1983 or an implied private right of action. It affirmed the district court’s summary judgment for the individual plaintiffs on their due process and ADA claims, except for one plaintiff’s ADA claim, which lacked evidence of a requested accommodation. The Eighth Circuit vacated the district court’s permanent injunction, finding it overbroad and issued without proper consideration of adequate legal remedies, and remanded for further proceedings. View "Holmes v. Bax" on Justia Law

After being discharged from her employment at Lamont Mortuary, Inc., Kayla Williams applied for unemployment insurance benefits in Arizona. A deputy from the Arizona Department of Economic Security (“the Department”) determined that Williams was eligible for benefits. Lamont Mortuary appealed, and after a hearing, the Department’s Tribunal reversed the initial decision, finding Lamont’s testimony more credible and concluding that Williams had been insubordinate, thereby disqualifying her from receiving benefits under Arizona law. Williams then petitioned the Unemployment Insurance Appeals Board, which adopted the Tribunal’s findings and affirmed the denial of benefits, adding that Williams had also failed to provide necessary passwords to her employer.Williams sought review in the Arizona Court of Appeals, which granted her application. Lamont Mortuary did not participate in the appeal, but the Department filed a brief defending the Board’s decision. Williams argued that the Department lacked standing to participate. The Court of Appeals agreed, declined to consider the Department’s brief, held that Williams was entitled to benefits, and awarded her attorney’s fees under A.R.S. § 12-348(A)(2).The Supreme Court of the State of Arizona granted review to address whether the Department has statutory standing to defend the Board’s decision in the Court of Appeals and whether it can be liable for attorney’s fees if it does so. The Supreme Court held that A.R.S. § 41-1993(B) grants the Department statutory standing to appear and defend the Board’s decision in the Court of Appeals and that the scope of its arguments is limited by statute to the administrative record and issues raised before the Board. The Court further held that A.R.S. § 12-348(H)(1) precludes a fee award against the Department in such appeals, as the exclusion is determined by the character of the underlying administrative proceeding. The Supreme Court vacated the Court of Appeals’ decision in part, reversed the fee award, and remanded for further proceedings. View "WILLIAMS v ARIZONA DEPARTMENT OF ECONOMIC SECURITY" on Justia Law

A former public-school teacher worked in Arizona from 1986 to 2001, accumulating over twelve years of credited service in the Arizona State Retirement System (ASRS). Upon leaving Arizona and moving to Pennsylvania to continue teaching, she joined Pennsylvania’s Public School Employees’ Retirement System (PSERS) in 2001. In 2007, she withdrew all funds (both employee and employer contributions) from her ASRS account and rolled them into a private retirement account, thereby terminating her membership and any future entitlement to benefits from ASRS. Later, she sought to purchase service credit in PSERS for her prior Arizona service.Her request to purchase service credit was denied by PSERS, which reasoned that the withdrawal of combined contributions from ASRS constituted receipt of a retirement benefit, making her ineligible under Section 8304(a) of the Retirement Code. This determination was upheld by the PSERS Executive Staff Review Committee and then by the Public School Employees’ Retirement Board. On further appeal, the Commonwealth Court of Pennsylvania affirmed the Board’s decision, relying on prior precedent and the view that the statutory purpose was to prevent “double dipping”—receiving credit in two retirement systems for the same service.The Supreme Court of Pennsylvania reviewed the case and reversed the lower courts’ decisions. The Court held that, under the unambiguous language of Section 8304(a), a PSERS member is only barred from purchasing service credit if they are currently “receiving,” “entitled to receive,” or “eligible to receive now or in the future” retirement benefits from another system. Because the appellant had already withdrawn her Arizona benefits and was no longer eligible for any current or future ASRS benefits, the statute did not prohibit her from purchasing PSERS service credit for her Arizona service. View "Esch v. PSERB" on Justia Law

A veteran who served in the Marine Corps, including a tour in Vietnam, began experiencing fatigue and underwent a medical evaluation at a Veterans Affairs Medical Center in 2010. His blood tests showed elevated lymphocyte counts. However, VA physicians in Florida diagnosed him with monoclonal B-cell lymphocytosis (MBL), not chronic lymphocytic leukemia (CLL), and did not inform him of a CLL diagnosis. Years later, after his condition worsened and he relocated to Tennessee, a VA oncologist diagnosed him with CLL and retroactively opined that his medical records met the diagnostic criteria for CLL since 2010. The veteran then applied for VA disability compensation. The VA assigned a 100% disability rating with an effective date of January 29, 2016, the date his claim was filed.The veteran appealed, arguing for an earlier effective date due to the alleged misdiagnosis and failure to inform him about his CLL. The Board of Veterans’ Appeals partially granted his request, assigning an effective date of January 29, 2015, but declined to go earlier, finding that the law did not allow equitable considerations to affect the effective date under 38 U.S.C. § 5110. The veteran then appealed to the United States Court of Appeals for Veterans Claims, raising arguments that the VA should be equitably estopped from enforcing § 5110’s effective date restrictions, and that those restrictions were unconstitutional as applied to him. The Veterans Court affirmed the Board’s decision.On further appeal, the United States Court of Appeals for the Federal Circuit affirmed the Veterans Court. The Federal Circuit held that equitable estoppel cannot override the effective date limitations of 38 U.S.C. § 5110, and that § 7331 does not create a statutory precondition to enforcement of § 5110. It also held that the statute’s effective date limitations were not unconstitutional as applied to the veteran’s circumstances. View "LEY v. COLLINS " on Justia Law

Two individuals who were victims of terrorist attacks sponsored by Iran obtained judgments against Iran under the Foreign Sovereign Immunities Act’s terrorism exception and were deemed eligible for compensation from the United States Victims of State Sponsored Terrorism Fund. The Fund is financed by criminal penalties and forfeitures related to certain offenses involving state sponsors of terrorism. After British American Tobacco and its subsidiary agreed to pay over $629 million in criminal penalties and forfeitures for conspiracies involving illicit business with North Korean entities, the Department of Justice allocated only a small fraction of those proceeds to the Fund. The Department’s allocation was based on its interpretation that only proceeds from offenses with a direct nexus to a state sponsor of terrorism should be deposited.The United States District Court for the District of Columbia granted summary judgment for the Department of Justice, upholding its interpretation of the relevant statutory funding provision. The district court reasoned that only proceeds from transactions or conduct occurring while North Korea was designated as a state sponsor of terrorism should be deposited into the Fund, and that the Department’s allocation was consistent with statutory requirements.Upon appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the district court’s decision de novo. The Court of Appeals held that the Department of Justice erred in its allocation. The statutory language requires all proceeds from violations of IEEPA and TWEA, including conspiracy offenses charged under IEEPA, to be deposited into the Fund regardless of any nexus to a state sponsor of terrorism. Additionally, for related criminal conspiracies such as BAT’s bank fraud conspiracy, if the offense originated from doing business with a state sponsor of terrorism, all proceeds must be deposited into the Fund. The Court reversed the district court’s judgment and remanded with instructions to enter summary judgment for the plaintiffs. View "Englehardt v. Blanche" on Justia Law

A patrol officer with the Anoka Police Department completed a 12-hour shift during which he responded to multiple calls, including emergency situations such as a domestic dispute involving a report of a child with a knife. The following day, the officer died from a vascular rupture. His widow applied for state line-of-duty death benefits, submitting medical evidence that the stressful nature of police work contributed to his fatal condition. While her application for federal death benefits was approved, the Commissioner of Public Safety denied her application for Minnesota death benefits, concluding the officer’s death did not meet the statutory criteria for being “killed in the line of duty.”After the Commissioner’s denial, the widow appealed to the Office of Administrative Hearings, where the Administrative Law Judge (ALJ) granted summary disposition in favor of the Commissioner. The ALJ found that the officer’s final shift did not involve “nonroutine stressful or strenuous physical law enforcement activity” as required by statute. The Minnesota Court of Appeals reversed, holding that there was a genuine issue of material fact regarding whether the officer engaged in such nonroutine activity during his last shift. The court also concluded that the definition of “killed in the line of duty” from prior Minnesota Supreme Court cases did not apply to deaths specifically addressed by the legislature in the statute.The Supreme Court of Minnesota reviewed the case and clarified the statutory presumption for certain heart-related deaths. The Court held that an emergency response is presumptively “nonroutine” under the statute, regardless of how frequently it occurs or how it is characterized by the agency. It also determined that the phrase “nonroutine stressful or strenuous physical” modifies all activities listed in the statute. Additionally, the Court held that if the statutory presumption does not apply or is rebutted, the officer’s estate may still prove line-of-duty death under the legal standard set forth in Kramer v. State, Peace Officers Benefit Fund, and Johnson v. City of Plainview. The decision of the Court of Appeals was affirmed in part and reversed in part. View "In re Public Safety Officer Death Benefit for Groebner" on Justia Law

A legal advocacy organization petitioned for a writ of mandamus to compel the Department of Veterans Affairs (VA) to update its mailing addresses, alleging that the VA continued to send correspondence to incorrect addresses despite repeated notifications of changes. The petitioner requested court intervention to ensure the VA updated its address records, ceased sending correspondence to wrong addresses, and imposed financial penalties for future errors.The United States Court of Appeals for Veterans Claims dismissed the petition as moot after the VA voluntarily corrected the addresses and created a policy to guide attorneys on updating their addresses. The VA also provided affidavits and a fact sheet to confirm these corrections. The petitioner subsequently sought attorney fees under the Equal Access to Justice Act (EAJA), asserting that the Veterans Court’s order requiring affidavits constituted the necessary “judicial imprimatur” for prevailing-party status. The Veterans Court denied the application, relying on Cavaciuti v. McDonough, and found there was no court-mandated decision on the merits and no material alteration to the parties’ legal relationship.On appeal, the United States Court of Appeals for the Federal Circuit reviewed whether the Veterans Court erred in denying attorney fees under EAJA. The Federal Circuit held that a court order requiring a party only to confirm voluntary corrective actions for the purpose of assessing mootness does not constitute sufficient judicial imprimatur to confer prevailing-party status under EAJA. The court found that the Veterans Court’s order did not address the merits of the petition or alter the legal relationship between the parties. The Federal Circuit therefore affirmed the Veterans Court’s denial of the EAJA application. View "VETERANS LEGAL ADVOCACY GROUP v. COLLINS " on Justia Law

The petitioner began working as an Operational Support Technician with the Federal Bureau of Investigation in Miramar, Florida, in 1987. Her duties required her physical presence at the office, and she commuted daily from her home. In December 2016, she was found to have engaged in workplace misconduct—specifically, being under the influence while on duty—and was removed from her position in July 2018. In April 2019, she applied for Federal Employees’ Retirement System (FERS) disability retirement benefits, claiming that recurring seizures prevented her from commuting to work and performing the essential duties of her position.The Office of Personnel Management denied her application and subsequent request for reconsideration, determining that she had not established that her medical condition rendered her unable to provide “useful and efficient service” in her position. The petitioner appealed to the Merit Systems Protection Board. An administrative judge affirmed OPM’s determination, finding insufficient evidence that she was unable to perform the essential functions of her job. The judge also rejected her argument that her inability to commute, due to seizures and lack of transportation options, should be considered in assessing her disability status. The full Board adopted the administrative judge’s findings.The United States Court of Appeals for the Federal Circuit reviewed the Board’s final decision. The court held that, under 5 U.S.C. § 8451(a)(1)(B), the statutory definition of disability for FERS benefits does not include an employee’s ability to commute; only the refusal of reassignment to a position within the commuting area is governed by such considerations under § 8451(a)(2)(A). The court also ruled that it is statutorily barred from reviewing factual determinations underlying OPM’s disability findings. Accordingly, the Federal Circuit affirmed the Board’s decision. View "CHAFIN v. OPM " on Justia Law

A former court reporter who worked for nearly four decades for a California county discovered, as she approached retirement, that the county had failed to enroll her in the state retirement system (CalPERS) for several years early in her employment. Upon learning this, she attempted to secure a complete employment record from the county, which CalPERS required to adjust her retirement benefits. The county failed to provide complete records, reportedly due to records being lost or destroyed, and provided only incomplete information to CalPERS. This left her unable to purchase prior service credit or receive full retirement benefits, causing her financial harm and forcing her to delay retirement.After filing a claim with the county and receiving no response, the plaintiff brought multiple causes of action in the Humboldt County Superior Court, including alleged violations of statutory duties and negligence against the county and individual employees. The trial court sustained the defendants’ demurrers, dismissing all statutory claims without leave to amend and granting leave to amend only the negligence claim. When the plaintiff submitted an amended complaint limited to negligence, the trial court again sustained the demurrer without leave to amend, finding no statutory duty supported the claim.The California Court of Appeal, First Appellate District, Division One, reviewed the case. It held that the plaintiff had stated valid causes of action against the county for violation of mandatory statutory duties to maintain personnel records and to enroll eligible employees in CalPERS under Government Code section 815.6. The court also held, in an unpublished portion, that the plaintiff stated a viable negligence claim against the individual defendants, with the county potentially vicariously liable. The appellate court reversed the trial court’s dismissal of these claims and remanded for further proceedings. View "Gibbs v. County of Humboldt" on Justia Law