Justia Public Benefits Opinion Summaries

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This case focuses on a Florida statute that concerns the inheritance rights of a child conceived from the eggs or sperm of a deceased person. Kathleen Steele, the appellant, had a child named P.S.S conceived through in vitro fertilization using her deceased husband's sperm. She sought survivor benefits from the Social Security Administration (SSA), claiming P.S.S. was entitled to such benefits as a child of Mr. Steele. The SSA denied the application, and the decision was upheld by an administrative law judge and a federal district court.On appeal, the U.S. Court of Appeals for the Eleventh Circuit certified two questions to the Supreme Court of Florida. The court only addressed the first question, which asked whether P.S.S was "provided for" in the decedent's will within the meaning of Florida Statute § 742.17(4).The Supreme Court of Florida ruled that "provided for" in this context means that the will must give something to the child as contemplated by the decedent when the will was made. The court found that Mr. Steele's will did not contemplate the possibility of children being conceived after his death nor did it provide any inheritance rights to such children. Therefore, the court concluded that P.S.S was not "provided for" in Mr. Steele's will within the meaning of the statute and was not eligible for a claim against the decedent's estate. The court did not address the second question certified by the Eleventh Circuit as the answer to the first question was determinative of the case. View "Steele v. Commissioner of Social Security" on Justia Law

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Kevin Ross filed for disability insurance benefits due to deep vein thrombosis in the left hip, a cervical spine disc replacement, and a bulging disc in the lumbar spine. Ross contended that these ailments rendered him incapable of working in the national economy. However, the Social Security Administration denied Ross's claim, and the administrative law judge (ALJ) affirmed the denial. Ross sought judicial review, but the United States District Court for the Eastern District of Arkansas affirmed the ALJ's decision.Ross appealed to the United States Court of Appeals for the Eighth Circuit, arguing that the ALJ overlooked his inability to move his neck up and down and his back limitations. He also argued that the ALJ improperly discredited his testimony regarding the severity of his symptoms. The appellate court held that substantial evidence supported the ALJ's decision, noting that the medical record contained contradictory findings about Ross's neck movement and back limitations. The court also found that the ALJ properly discredited Ross's testimony since the evidence as a whole was inconsistent with Ross's claims. The court affirmed the district court's decision, holding that Ross was not disabled and could work as a document preparer and surveillance system monitor. View "Ross v. O'Malley" on Justia Law

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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

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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

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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

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The United States Court of Appeals for the Ninth Circuit affirmed the decision of the district court, which upheld the Commissioner of Social Security's denial of a claimant's application for supplemental security income. The claimant argued that the Social Security Administration's 2017 revised regulations for evaluating medical opinions were partially invalid because they did not provide a reasoned explanation for permitting an administrative law judge to avoid articulating how he or she accounts for the "examining relationship" or "specialization" factors under the Social Security Act or the Administrative Procedure Act (“APA”). The court found that the Commissioner's decision to promulgate the 2017 medical evidence regulations fell within his wide latitude to make rules and regulations, particularly those governing the nature and extent of the proofs and evidence to establish the right to benefits. The court also joined the Eleventh Circuit in holding that the regulations were valid under the APA, as the agency's response to public comment and reasoned explanation for the regulatory changes established that the regulations were not arbitrary or capricious. View "CROSS V. O'MALLEY" on Justia Law

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Erik Bertaud, who suffered serious injuries when a tree branch fell on his head, applied for disability insurance benefits and supplemental security income from the Social Security Administration. His application was denied, and he appealed. The Appeals Council remanded the case twice, but after the third denial, Bertaud's request for review was denied, making the ALJ's decision the final decision of the Commissioner. Bertaud then sought judicial review, arguing that the ALJ had failed to develop the record of his disability, pointing to over 800 pages of new medical evidence. The district court denied Bertaud's motion for summary judgment and affirmed the Commissioner's decision, and Bertaud appealed to the United States Court of Appeals for the Seventh Circuit.The court held that although an ALJ has a duty to develop a full and fair record, this duty is limited when the claimant is represented by an attorney. The claimant's duty to submit evidence is ongoing and covers any additional related evidence they become aware of. The court noted that Bertaud was represented and his attorney had confirmed that the evidence was complete and supplemented the record when necessary. Therefore, the court concluded that the ALJ did not fail to develop Bertaud's medical record. The court affirmed the district court's decision denying Bertaud's motion for summary judgment and affirming the decision of the Commissioner. View "Bertaud v. O'Malley" on Justia Law

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The case involves the plaintiff-appellant, Chris Martin, who suffered a back injury in June 2016 and stopped working. He sought medical attention in February 2018 and was diagnosed with a spine disorder in May 2018. Martin applied for Social Security disability benefits and was awarded supplemental security income after an administrative law judge (ALJ) found him disabled under the Social Security Act's stringent definition. However, he was denied disability insurance benefits because his insured status for those benefits had expired on December 31, 2017, a few weeks before he was found to have been disabled. Martin appealed, arguing that the ALJ should have consulted an additional medical expert to determine whether he was disabled earlier, before his insured status lapsed. The United States Court of Appeals for the Seventh Circuit concluded that the ALJ did not abuse her discretion in deciding not to consult another medical expert. The court explained that Social Security Ruling 18–01p allows an ALJ to decide whether to consult an additional medical expert to answer that question. Therefore, the court affirmed the denial of disability insurance benefits. View "Martin v. Kijakazi" on Justia Law

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The case before the Supreme Court of the State of Delaware concerned an appeal by Carrah LeBoon Odell against an order from the Superior Court of the State of Delaware. The order affirmed a decision made by the Unemployment Insurance Appeal Board (UIAB) that upheld decisions by an appeals referee concluding that Odell was liable to repay overpaid unemployment benefits totaling $7,139.Odell had originally filed a claim for unemployment insurance benefits after her employer, Allied Universal, reduced her hours. She later obtained a second job at Rater Labs and reported income from both employers to the Department of Labor. She received traditional unemployment benefits and Federal Pandemic Unemployment Compensation under the CARES Act for a period. It was later determined that Odell’s total income during the period was too high to qualify for unemployment benefits, and the benefits she received were therefore an overpayment subject to recoupment by the Department.Odell appealed the overpayment determinations, admitting that she was ineligible for traditional unemployment benefits during the period in question because her income was too high. She requested a waiver of the obligation to repay the benefits, arguing that she met the conditions for a repayment waiver established by the US Department of Labor’s instructions to states regarding processing overpayment waivers under the CARES Act.The UIAB affirmed the appeals referee’s decision. Odell then appealed to the Superior Court, which also affirmed the Board’s decision.Odell appealed to the Supreme Court of the State of Delaware, which concluded that the Board’s decision was supported by substantial evidence and free from legal error. The Supreme Court ruled that Odell was liable for repayment, regardless of the cause of the overpayment. Her arguments concerning the Department’s computer system and discovery relating to that system did not establish reversible error. Furthermore, her argument that her repayment obligation should have been waived did not establish reversible error as repayment waivers were not available at the time of the proceedings below.Therefore, the Supreme Court affirmed the judgment of the Superior Court. View "Odell v. Unemployment Insurance Appeal Board" on Justia Law

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This is a dispute regarding a claim for Disability Insurance Benefits and Supplemental Security Income under the Social Security Act, brought by the plaintiff-appellant, Heather Tutwiler. The United States Court of Appeals for the Seventh Circuit affirmed the lower court's ruling that Ms. Tutwiler was not disabled within the meaning of the Social Security Act. The court found that the plaintiff had not engaged in substantial gainful employment since the onset date of her condition, and that her impairments significantly limited her ability to perform basic work activities. However, these impairments did not meet or equal the severity of any impairments listed in the Social Security regulations that lead to automatic findings of disability. The court noted that Ms. Tutwiler had the residual functional capacity to perform sedentary work with some additional restrictions. The court also found that jobs within Ms. Tutwiler’s abilities existed in the economy in such numbers that she was not disabled under the Social Security Act. The court held that the ALJ's decision was supported by substantial evidence and was not otherwise contrary to law. View "Tutwiler v. Kijakazi" on Justia Law