Justia Government & Administrative Law Opinion Summaries

Gayheart applied for Social Security disability insurance benefits in 2005 due to manifestations of anxiety, panic disorder, bipolar disorder, and depression. After an initial denial and three separate hearings, an administrative law judge (ALJ) found that the limitations caused by Gayheart’s impairments did not preclude him from performing a significant number of jobs available in the national economy and denied Gayheart’s application. Gayheart’s request for an administrative appeal was denied. The Report and Recommendation issued by the federal court’s assigned magistrate judge concluded that the ALJ’s decision was not supported by substantial evidence and that Gayheart should be awarded benefits. But the district court sustained the Commissioner’s objections and affirmed the ALJ’s decision. The Sixth Circuit reversed and remanded, holding that the ALJ failed to weigh the medical opinions according to 20 C.F.R. 404.1527. View "Gayheart v. Comm'r of Soc. Sec." on Justia Law

Plaintiffs, teaching hospitals, received Medicare payments to offset the costs associated with training "full-time equivalent" residents and intern physicians (FTEs). In 1997, Congress capped those payments in such a way that the number of FTEs the hospitals trained in 1996 would dictate the maximum reimbursement in all future years. Although the parties agreed that the 1996 data was not accurate, the Secretary believed that this predicate fact could not be corrected outside the three-year reopening window. The court held that the reopening regulation allowed for modification of predicate facts in closed years provided the change would only impact the total reimbursement determination in open years. Alternatively, the court agreed with the district court that the Secretary had acted arbitrarily in treating similarly situated parties differently. The court rejected the Secretary's claim that the Medicare Act, 42 U.S.C. 1395 et seq., would not allow the intermediary to change the 1996 GME resident count without changing the corresponding reimbursement amount, which all parties conceded would constitute a reopening of an "Intermediary determination." Accordingly, the court affirmed the judgment. View "Kaiser Foundation Hospitals v. Sebelius" on Justia Law

Plaintiffs, thirteenth North Carolina residents who lost access to in-home personal care services (PCS) due to a statutory change, brought suit challenging the new PCS program. The district court granted plaintiffs' motions for a preliminary injunction and class certification. Defendants appealed, raising several points of error. The court agreed with the district court's conclusion that a preliminary injunction was appropriate in this case. The court held, however, that the district court's order failed to comply with Federal Rule of Civil Procedure 65 because it lacked specificity and because the district court neglected to address the issue of security. Accordingly, the court remanded the case. View "Pashby v. Delia" on Justia Law

Claimants appealed a district court judgment that affirmed Job Service of North Dakota's decision to deny them unemployment benefits. Upon review of the administrative record and the plain language of N.D.C.C. 52-06-02(4), the Supreme Court concluded that claimants were only disqualified from unemployment compensation for employee-initiated work stoppages due to labor disputes, not to locked out Claimants as in this case. Accordingly, the Court reversed the district court's judgment and remanded the case back to Job Service for further proceedings. View "Olson v. Job Service" on Justia Law

Full Life Hospice participates in the federal Medicare program. It sought reimbursement for hospice services provided to Medicare recipients from the Department of Health and Human Services (HHS). A fiscal intermediary, acting on behalf of HHS, later contested some of these reimbursements and demanded repayment of funds that it claimed were distributed in excess of a spending cap. Full Life unsuccessfully challenged HHS intermediary’s determination through an administrative appeal, which was denied as untimely. On appeal to the district court, the court found no basis to excuse Full Life's untimely challenge. Upon review, the Tenth Circuit agreed with the district court that it lacked subject matter jurisdiction because of Full Life's failure to file a timely administrative appeal. View "Full Life Hospice v. Sebelius" on Justia Law

The State appealed from the district court's order enjoining it from requiring plaintiff to submit to a suspicionless drug test pursuant to Section 414.0652 of the Florida Statutes, as a condition for receipt of government-provided monetary assistance for which he was otherwise qualified. Plaintiff applied for financial assistance benefits for himself and his son through Florida's Temporary Assistance for Needy Families program (TANF). The court held that the district court did not abuse its discretion in granting the preliminary injunction enjoining the State from enforcing the statute because the court concluded that the State had failed to establish a substantial special need to support its mandatory suspicionless drug testing of TANF recipients. View "Lebron v. Secretary, FL Dept. of Children and Families" on Justia Law

Petitioner appealed from the district court's judgment affirming the Commissioner's denial of his application for disability benefits. The court held that the ALJ erred in her treatment of plaintiff's claim that he suffered from fibromyalgia by failing to accord the proper weight to the opinion of plaintiff's treating physician, by misconstruing the record, and by failing to evaluate the claim in light of medically accepted diagnostic criteria. The court also held that the ALJ's determination that plaintiff could perform light work was not supported by substantial evidence, and that the ALJ further erred by not determining whether plaintiff's reaching limitation was non-eligible and would therefore require the testimony of a vocational expert. Accordingly, the court vacated and remanded for further proceedings. View "Selian v. Astrue" on Justia Law

Appellant, a forty-eight-year-old who lived independently for two decades, had "borderline intellectual functioning," an expressive language disorder, and a learning disorder. Appellant applied for Home and Community Based Services (HCBS), a federal-state Medicaid Waiver program that provides assistance to individuals with developmental disabilities. The South Dakota Department of Human Services (the Department) denied Appellant's application, determining that Appellant was not eligible for HCBS. After a hearing, an ALJ affirmed the Department's denial. The circuit court affirmed. The Supreme Court also affirmed, holding that the ALJ did not clearly err in finding that Appellant did not qualify for benefits, as the evidence indicated that Appellant was a generally independent client who was able to function with little supervision or in the absence of a continuous active treatment program. View "Nelson v. Dep't of Social Servs." on Justia Law

Prasch worked as a mail carrier for the Postal Service until suffering a work-related injury, compensable under the Federal Employees’ Compensation Act. He received benefits from the Office of Workers’ Compensation Programs from December 2007 until October 2008. Prasch applied for disability retirement. OPM approved his application and deposited $14,640.27, representing retroactive retirement annuity payments from December 2007 through the approval of his application. OPM paid him another $5,869.60 in retirement annuity benefits before determining that Prasch had received FECA disability benefits from OWCP during the period that OPM was paying him retirement annuity benefits. Because governing statutes prohibit dual benefits, OPM adjusted the commencement date of Prasch’s retirement annuity and computed an overpayment of $14,703.62.and sent a proposed repayment schedule. Prasch requested a waiver of the repayment obligation, lower installments, or a compromise payment, but he did not ask for reconsideration of OPM’s decisions as to the existence of the overpayment or its amount. OPM affirmed its initial decision, finding that Prasch should have known that he could not receive dual benefits and rejecting his claim of financial hardship, but extended the time for repayment. The Merit Systems Protection denied an appeal. The Federal Circuit affirmed. View "Prasch v. Office of Pers. Mgmt." on Justia Law

Appellant Habib Sadid, a former tenured professor of civil engineering at Idaho State University, appealed an Industrial Commission Order that reversed the Department of Labor Appeals Examiner's grant of unemployment benefits to Appellant after he was terminated by Idaho State University. Upon review, the Supreme Court concluded that the Commission's finding of misconduct was supported by substantial and competent evidence. As such, the Court affirmed the Industrial Commission's order. View "Sadid v. Idaho State University" on Justia Law