Justia Government & Administrative Law Opinion Summaries

Beardsley was 49 years old when she fell and injured her knee. She had worked as a machine operator, assembler, inspector, and cashier. After the injury, she applied for disability insurance benefits and supplemental security income. Her doctors determined that she had meniscal tears and a ruptured ligament, compounded by obesity and worsening osteoarthritis. She declined surgery but received injections for the arthritis. Dr. Banyash examined her on behalf of the Social Security Administration and opined that pain and weakness restricted her ability to walk, stand, climb stairs, crouch, and kneel, but she was capable of sedentary work. Given Beardsley’s age and skills, a finding that she was capable of only sedentary work would have qualified her as disabled at the time under the grid SSA uses for making that determination. Another agency physician subsequently judged her able to stand or walk for about six hours of an eight-hour workday. The ALJ denied benefits, finding that she could still perform a range of light work. Beardsley argued that the ALJ gave too little weight to the opinion of the examining doctor and too much weight to an erroneous view of her daily activities, particularly care she provided for her elderly mother and that the ALJ improperly held against her the decision not to seek surgery. The district court affirmed the denial of benefits. The Seventh Circuit reversed and remanded, finding that errors undermined the “logical bridge” between evidence and conclusion. View "Beardsley v. Colvin" on Justia Law

Townsend applied for social security disability benefits and supplemental security income in 2003, at age 44, claiming that she had become incapable of full‐time gainful employment in May 2002 when she had stopped working as a result of multiple physical and psychiatric ailments, including fibromyalgia. In 2012 an ALJ decided that she had become totally disabled in November 2008. By the time that decision was rendered she had died (of pulmonary diseases apparently unrelated to the ailments alleged to have made her totally disabled). Her father was substituted for her. The district court upheld the decision. The Seventh Circuit reversed and remanded, noting multiple errors in determining the onset of total disability. View "Williams v. Colvin" on Justia Law

This case involved a petition for injunctive and declaratory relief brought by plaintiffs Harbor Homes, Inc. and Gary Dube, Thomas Taylor, Cynthia Washington, and Arthur Furber against defendants the New Hampshire Department of Health and Human Services (DHHS), the Commissioner of DHHS, the Associate Commissioner of DHHS, and the Administrator of the Bureau of Behavioral Health seeking, in part, to enjoin DHHS from denying the individual plaintiffs the right to obtain Medicaid-funded services from their chosen provider, Harbor Homes. The individual plaintiffs received Medicaid-funded rehabilitative services from Harbor Homes. Since 1991, Harbor Homes participated in New Hampshire's Medicaid program pursuant to a Medicaid Provider Enrollment Agreement. On June 23, 2008, Harbor Homes entered into an interagency agreement (IAA) with a community mental health program, Community Council of Nashua, NH, now known as Greater Nashua Mental Health Center (GNMHC), which authorized Harbor Homes to provide certain Medicaid-funded rehabilitative services to GNMHC patients. In February 2011, Harbor Homes learned that GNMHC did not intend to renew its IAA and that the Medicaid reimbursable services provided by Harbor Homes would be transitioned to GNMHC. This was done pursuant to Administrative Rule He-M 426.04(a)(2), which meant that Harbor Homes would no longer have an IAA with a community mental health provider, and it would no longer be permitted to provide Medicaid funded mental health services to approximately one hundred and forty of its clients, including the individual plaintiffs in this case. Plaintiffs filed a petition for injunctive and declaratory relief, seeking a court order enjoining DHHS from "terminating or limiting Harbor Homes' status as a qualified Medicaid provider" and to direct the State to allow the individual plaintiffs to obtain community mental health services from Harbor Homes, the provider of their choice. Following two hearings, the court denied the plaintiffs' request for a preliminary injunction. Thereafter, all parties moved for partial summary judgment on the plaintiffs' claim that DHHS's reliance upon the IAA requirement as a reason to terminate Harbor Homes' status as a qualified Medicaid provider was improper because the requirement was invalid both on its face and as applied in this case. Plaintiffs appealed rulings of the Superior Court that denied their summary judgment motions and granting the defendants' cross-motions for summary judgment on two counts in the plaintiffs' petition. Upon review of the matter, the Supreme Court reversed the Superior Court's ruling that New Hampshire Administrative Rules, He-M 426.04(a)(2) did not violate the federal Medicaid Act. The case was remanded for further proceedings. View "Dube v. New Hampshire Dept. of Health & Human Svcs." on Justia Law

Robert Campbell quit his job as a school teacher in anticipation of accompanying his wife to Finland on her Fulbright grant. Campbell applied for unemployment benefits for the months between his resignation in June 2010 and his family's planned departure in February 2011. His request was denied because the Department of Employment Security determined that Campbell did not qualify for benefits as claimed under RCW 50.20.050(2)(b)(iii), known as the "quit to follow" provision. On appeal, the superior court reversed, but the Court of Appeals reinstated the agency action. The Supreme Court affirmed the Court of Appeals and held that Campbell's resignation from his job seven months before the planned relocation was not reasonable as contemplated by the statute. View "Campbell v. Dep't of Emp't Sec." on Justia Law

Plaintiff’s spouse (Spouse) applied to the Commissioner of Social Services (Department) for Medicaid benefits. After a review of the combined assets of both Spouse and Plaintiff, the Department concluded that Spouse was not eligible to receive Medicaid benefits. A hearing officer denied Plaintiff’s appeal, as did the superior court. The Supreme Court affirmed, holding that the trial court correctly concluded that the Department did not act arbitrarily or abuse its discretion in finding that the Department applied the correct eligibility and availability of assets criteria when evaluating the application for Medicaid benefits submitted by Spouse. View "Palomba-Bourke v. Comm'r of Soc. Servs." on Justia Law

Plaintiffs, Medicaid beneficiaries with near total disabilities, filed suit after being denied coverage for ceiling lifts under a categorical exclusion in the state's implementing Medicaid regulations. The district court granted summary judgment for the state. The court concluded that, under binding precedent, plaintiffs have an implied private cause of action under the Supremacy Clause to pursue their challenge; the state must comply with the requirements of the Medicaid Act, 42 U.S.C. 1396 et seq., but the Act does not preempt the state's categorical exclusions; and therefore, the court affirmed the grant of summary judgment and denied the motion to vacate. View "Detgen, et al. v. Janek" on Justia Law

An ALJ denied plaintiff's application for disability insurance benefits, concluding that she was not disabled because there were jobs she could have performed during the relevant period. The Appeals Council then denied review and plaintiff appealed the Commissioner's final decision to the district court. In this appeal, the government challenged the district court's reversal of the Commissioner's decision. The court reversed and affirmed the Commissioner's final decision, concluding that the ALJ's decision was supported by substantial evidence on the record. View "Turpin v. Colvin" on Justia Law

Petitioners were two medical providers whose patients included individuals insured by the State’s primary health benefit plan. The State Comptroller reviewed Petitioners’ billing records as part of an audit of billing practices in the health care industry for claims paid by the State. While Petitioners conceded that the State paid eighty percent of the costs of their services, Petitioners challenged the Comptroller’s authority to audit their books. Supreme Court concluded that the Comptroller lacked constitutional authority to audit Petitioners because Petitioners were “not a political subdivision of the State.” The Appellate Division modified Supreme Court’s orders to reinstate the audits. The Court of Appeals affirmed, holding that the State Constitution does not limit the Comptroller’s authority to audit, as part of its audit of State expenditures, the billing records of private companies that provide health care to beneficiaries of a State insurance program. View "Martin H. Handler, M.D., P.C. v. DiNapoli" on Justia Law

Plaintiff appealed the district court's order denying his motion for attorney's fees under the Equal Access to Justice Act (EAJA), 28 U.S.C. 2412. The court concluded that the underlying agency action lacked a reasonable basis in law because the Social Security ALJ disregarded competent lay witness evidence on plaintiff's symptoms without comment. The court concluded that, because the ALJ disregarded competent lay witness evidence without comment, the position of the United States in the underlying action was not substantially justified. Because the government's underlying position was not substantially justified, the court awarded fees, even if the government's litigation position may have been justified. Therefore, plaintiff was entitled to an award of attorney's fees. Accordingly, the court reversed and remanded. View "Tobeler v. Colvin" on Justia Law

In 2003 the Social Security Administration denied DeLong’s applications for Disability Insurance Benefits. After each of three hearings, the ALJ concluded that DeLong was not disabled. After the third determination, the Appeals Council declined further review. In 2010, DeLong challenged the denial under 42 U.S.C. 405(g) and 1383(c)(3). The district court vacated and remanded, concluding that the ALJ had failed to provide ‘good reasons’ for the weight he gave to the opinions of treating physicians,” but rejected two other claims, noting that credibility determinations are peculiarly within the province of the ALJ, that the ALJ had not mischaracterized underlying medical evidence, and no error in the consideration of lay opinion evidence. DeLong sought attorney fees under the Equal Access to Justice Act, 28 U.S.C. 2412, contending that the denial of benefits and defense of the denial had lacked substantial justification. The district court denied the motion, reasoning that the agency’s position was substantially justified because the court had rejected all but one argument; DeLong had improperly attempted to present evidence in court that she had not presented to the ALJ; the record did not “strongly establish” entitlement to benefits; and the reversal was on procedural, not substantive, grounds. The Sixth Circuit affirmed. View "DeLong v. Comm'r of Social Sec." on Justia Law