Justia Government & Administrative Law Opinion Summaries

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

The plaintiff, Robert Conway, appealed a decision by the district court that upheld the denial of his social security benefits by an administrative law judge (ALJ). The ALJ had found that Conway could perform "medium work" based on the testimony of a vocational expert. Under Terry v. Saul, the term "medium work" was presumed to imply a six-hour standing and walking limitation.However, Conway argued that this presumption was rebutted during the cross-examination of the vocational expert. When asked if someone could perform medium work if they were only able to be on their feet for six hours maximum, the expert responded that the three sample occupations provided would not be possible and it would be difficult to provide substitute unskilled, medium occupations.The United States Court of Appeals for the Ninth Circuit agreed with Conway, finding that the vocational expert's significantly different responses revealed that the expert did not understand the ALJ’s hypothetical to impliedly include a six-hour standing and walking limitation. As such, the expert’s response to the ALJ’s question had no evidentiary value to support the ALJ’s finding that Conway could perform jobs in the national economy. The court concluded that the error was not harmless and reversed the district court’s judgment, remanding the case to the Commissioner of Social Security for further proceedings. View "CONWAY V. O'MALLEY" on Justia Law

In this appeal before the United States Court of Appeals for the Seventh Circuit, the plaintiff, Kelly Chavez, had been denied supplemental security income due to her various mental and physical impairments. The administrative law judge (ALJ) at a hearing found that Chavez could perform jobs that existed in significant numbers in the economy. This decision was affirmed by the district court, leading to this appeal. Chavez contended that the vocational expert's testimony, which the ALJ relied on, did not provide substantial evidence supporting the ALJ's decision.The vocational expert, Sarah Holmes, testified that a person with Chavez's age, background, and ability could perform several light exertion jobs, such as cleaner, office helper, and storage rental clerk. She used a software program, Job Browser Pro, to estimate the number of jobs, which uses data from the Bureau of Labor Statistics.Chavez's main argument was that Holmes did not explain Job Browser Pro's underlying formula, thereby rendering her testimony unreliable. However, the court held that Holmes's testimony provided substantial evidence for the ALJ's finding. The court highlighted that Holmes used a generally accepted source of job numbers, provided a straightforward overview of how the source worked, offered to provide additional information about the source's underlying formula, and identified jobs commonly found in the national economy. Therefore, the court affirmed the district court's judgment. View "Chavez v. O'Malley" on Justia Law

The plaintiff, Todd Hess, applied for supplemental security income, disability insurance benefits, and disabled adult child benefits, all of which are administered by the Social Security Administration. While his claims for supplemental security income and disability insurance benefits were approved, his claim for disabled adult child benefits was denied. To qualify for disabled adult child benefits, Hess had to prove that he had a disability that continued uninterrupted from before his 22nd birthday until the filing of his application for benefits. He claimed that his depression, panic disorder, obsessive-compulsive disorder, and other impairments made him disabled during that entire period. However, after two hearings, an Administrative Law Judge disagreed, concluding that Hess was disabled as of June 9, 2009, but not before then. The ALJ's decision was based on gaps in Hess's treatment history, notes from his physicians, and occasional work he performed as an independent contractor. The Appeals Council did not assume jurisdiction, and the district court found that the ALJ's decision was supported by substantial evidence. The United States Court of Appeals for the Seventh Circuit agreed and affirmed the judgment of the district court. View "Hess v. O'Malley" on Justia Law

In the case before the Court of Appeal of the State of California First Appellate District Division Two, the appellant, Debra Abney, challenged the decision of the State Department of Health Care Services and the City and County of San Francisco to consider money garnished from her Social Security payments as income for the purposes of determining her eligibility for benefits under Medi-Cal.Abney's Social Security payments were being reduced by nearly $600 each month to satisfy a debt she owed to the IRS. The authorities considered this garnished money as income, which led to Abney being ineligible to receive Medi-Cal benefits without contributing a share of cost. Abney argued that the money being garnished was not income “actually available to meet her needs” under the regulations implementing the Medi-Cal program.The trial court rejected Abney's argument, and she appealed. The Court of Appeal affirmed the trial court's decision. The Court of Appeal held that the tax garnishment was "actually available" to meet Abney's needs because it benefitted her financially by helping to extinguish her debt to the IRS. Therefore, the garnished money was correctly considered as income for the purpose of calculating her eligibility for the Medi-Cal program. View "Abney v. State Dept. of Health Care Services" on Justia Law

This case arose from an appeal against the grant of summary judgment by a district court on a claim related to disability benefits. The appellant, Emily Seago, had contended that Nancy Berryhill was unlawfully serving as the acting Social Security Commissioner in July 2018 when she ratified the appointment of the Administrative Law Judge who later denied Seago’s claim.The United States Court of Appeals for the Fifth Circuit rejected Seago's argument and affirmed the district court’s grant of summary judgment. The court held that Berryhill was lawfully serving as Acting SSA Commissioner under 5 U.S.C. § 3346(a)(2) when she ratified the appointments of all SSA Administrative Law Judges in July 2018.The court noted that 5 U.S.C. § 3346(a) provides for two independent periods of acting service, during the 210-day period following a vacancy, and for the duration of a nomination's pendency in the Senate. The court found that these periods can operate independently, as indicated by the use of the word "or" to separate the two subsections. The court noted that the statutory text does not suggest that service under one subsection excludes someone from also serving under the other.The court also found that this interpretation aligned with the statutory purpose, providing an incentive for the President to submit timely nominations without denying vital public services to the American people due to delays in the Senate confirmation process. View "Seago v. O'Malley" on Justia Law