Justia Government & Administrative Law Opinion Summaries

These consolidated cases involved claims for survivors' benefits under the Black Lung Benefits Act, 30 U.S.C. 901 et seq. Petitioners, the coal mine operators responsible for payment of respondents' benefits, petitioned for review, claiming that principles of res judicata foreclosed respondents - each of whom previously and unsuccessfully sought survivors' benefits under the Act - from relying on a recent amendment to the Act to pursue benefits again through a "subsequent claim." The court affirmed the Board's awards, concluding that res judicata did not bar the subsequent claims because the amendment created a new cause of action that was unavailable to respondents when they brought their initial claims. View "Union Carbide Corp. v. Richard" on Justia Law

The Clinics filed suit challenging California Welfare and Institutions Code 14131.10, which eliminated certain Medi-Cal benefits that the state deemed optional, including adult dental, podiatry, optometry, and chiropractic services. The court reversed the district court's holding that the Clinics have a private right of action to challenge the Department's implementation of the state plan amendments (SPA) prior to obtaining approval; affirmed that the Clinics have a private right of action to bring a claim pursuant to 42 U.S.C. 1983 challenging the validity of section 14131.10; and reversed the district court's interpretation of the Medicaid Act, 42 U.S.C. 1396 et seq., holding that section 14131.10 impermissibly eliminated mandatory services from coverage. View "California Ass'n of Rural Health Clinics v. Douglas" on Justia Law

Plaintiffs, several nursing homes approved by the Iowa Department of Human Services (DHS) as Medicaid providers, submitted annual reports disclosing their income and expenses to DHS. DHS used the reports to calculate the Medicaid per diem reimbursement rates for the nursing homes. Some of the facilities' expenses were disallowed by DHS, and DHS reduced reimbursement rates accordingly. The facilities appealed the adjustments. The director of human services upheld the action. The district court affirmed. The court of appeals reversed, concluding that the DHS rules did not support its decision that the disputed costs were not allowable. The Supreme Court affirmed, holding that DHS's exclusion of the facilities' lab, x-ray, and prescription drug costs from the nursing homes' reports was based on an incorrect interpretation of its rules. View "Sunrise Ret. Cmty. v. Iowa Dep't of Human Servs." on Justia Law

Federal employees who are members of the National Guard are entitled to up to 15 days of annual military leave “without loss in pay, time, or performance or efficiency rating,” 5 U.S.C. 6323(a)(1). Before a 2000 amendment, the Office of Personnel Management interpreted the section as providing 15 calendar days of leave, rather than 15 workdays; federal employees who attended reserve training on non-work days were charged military leave. The Federal Circuit held that even before 2000, federal agencies were not entitled to charge employees military leave on non-workdays. Tierney worked at the DEA, 1974-2001, and was a member of the Air National Guard. He filed a Merit Systems Protection Board claim that the DEA charged him military leave for reserve duty on 44 non-workdays, so that he took annual leave or unpaid leave for military duty. An AJ ordered DEA to compensate Tierney for 17 days. The full Board reversed, finding that the Military Leave Summary and Tierney’s testimony were based solely on his military records and on speculation that DEA improperly charged military leave on intervening non-workdays and that the evidence was insufficient to prove that DEA charged him military leave on non-workdays or that he used annual leave for reserve duties. The Federal Circuit reversed and remanded, concluding that the decision was not supported by substantial evidence. View "Tierney v. Dep't of Justice" on Justia Law

Plaintiff-Appellant Tyla Newbold appealed a magistrate judge's order that granted her Social Security benefits from October 2006 to November 2007, but denied them thereafter. The Commissioner of the Social Security Administration determined Plaintiff had been disabled during that period due to physical and mental impairments, but that she recovered and the disability ceased. The issue on appeal to the Tenth Circuit was whether the administrative law judge (ALJ) used the proper medical-improvement standard in deciding Plaintiff ceased being disabled. Finding that the ALJ used the proper standard, the Tenth Circuit affirmed. View "Newbold v. Astrue" on Justia Law

Catholic Health filed suit under the Administrative Procedure Act (APA), 5 U.S.C. 500 et seq., challenging the agency's interpretation of the Medicare statute and its application to the 1997 cost-reporting period. The district court held that the Secretary's decision was unlawful because the agency, in calculating reimbursements owed for a 1997 cost-reporting period, had retroactively applied a 2004 rulemaking without congressional authorization. The court concluded that the policy on which the agency relied was first announced in an adjudication in 2000, not in the 2004 rulemaking; the agency's interpretation of the statute was permissible; the denial of reimbursements was not arbitrary and capricious; and Catholic Health had not shown that it relied to its detriment on the position the agency allegedly held before 2000. Accordingly, the court reversed the judgment of the district court. View "Catholic Health Initiatives Iowa Corp. v. Sebelius" on Justia Law

Plaintiffs appealed the Secretary's denial of their claims for Medicare coverage for dental services. Plaintiffs contended that this denial was premised on the Secretary's unreasonable interpretation of the Medicare Act, Pub. L. No. 89-97, 79 Stat. 286, which contravened the intent of Congress and violated plaintiffs' right to equal protection under the Fifth Amendment. The court concluded that, although the statutory provision for exclusion of dental services was ambiguous in the sense that plausible divergent constructions could be urged, the Secretary's interpretation of the statute was reasonable. The court also concluded that the Secretary's statutory interpretation warranted Chevron deference and the Secretary's statutory interpretation was reasonable. Accordingly, the court affirmed the judgment. View "Fournier v. Sebelius" on Justia Law

Plaintiffs, a class of Medicaid beneficiaries who suffered from severe developmental disabilities, sued the NCDHHS, PBH, and the director of PBH, alleging that defendants violated their rights under the Medicaid statute and the Due Process Clause of the Fourteenth Amendment by reducing their health care services without notice and an opportunity for a hearing. On appeal, PBH and the director challenged the district court's entry of a preliminary injunction. However, the NCDHHS did not join the appeal. Given that the NCDHHS had decided not to litigate the appeal, the court concluded that the Medicaid statute, 42 U.S.C. 1396a(a)(5), and accompanying regulations precluded PBH from appealing in the absence of the NCDHHS. Accordingly, the court dismissed the appeal. View "K.C. v. Shipman" on Justia Law

Southwest appealed the district court's dismissal of its claim regarding the Medicare Part D statute, 42 U.S.C. 1395w-101 et seq., for lack of subject matter jurisdiction. Citing Shalala v. Illinois Council on Long Term Care, Southwest argued that its claim provided a narrow exception to 42 U.S.C. 405(h)'s requirement that required a plaintiff to exhaust administrative remedies before filing a claim in federal court. The court concluded that caselaw interpreting the application of section 405(h) to Medicare claims emphasized that the Illinois Council exception was extremely narrow and appropriately applied only in cases where judicial review would be entirely unavailable through the prescribed administrative procedures. Because Southwest has not carried its heavy burden of showing that the Illinois Council exception applied, the court affirmed the district court's order dismissing the suit. View "Southwest Pharmacy Solutions, Inc. v. Centers for Medicare & Medicaid, et al" on Justia Law

Claimant William Stewart appealed a decision of the appeal tribunal, as affirmed by the appellate board of the New Hampshire Department of Employment Security (DES) that denied his application for unemployment benefits. Stewart worked as the code enforcement director for the City of Laconia from March 14 to June 29, 2011. Following his termination, Stewart applied for unemployment benefits. A DES certifying officer denied the application. The officer determined that Stewart did not have annual earnings of at least $1,400 in two of four quarters of his alternate base period. Stewart appealed the decision to the tribunal. He argued that he had earnings of at least $1,400 in both the third and fourth quarters of his alternate base period. Following a hearing, the tribunal affirmed the decision denying Stewart’s claim. Stewart argued on appeal to the Supreme Court that the tribunal erred in concluding that he had insufficient quarterly earnings under RSA 282-A:25 to establish a claim for benefits. Upon review, the Supreme Court reversed and remanded, finding that DES’s reliance on its decision in "Appeal of Tennis" was misplaced. View "Appeal of William Stewart" on Justia Law