Justia Public Benefits Opinion Summaries

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 case involves a claimant, Isaac Flowers, who applied for Social Security Disability benefits due to various health issues including back, neck, shoulder, and joint problems, obesity, vision loss in one eye, and depression and opioid dependence. The Administrative Law Judge (ALJ) initially denied his claim, deeming that he could perform "sedentary work". Later, Flowers applied for benefits again, and the ALJ denied his claim again, this time finding that he could perform "light work", a classification slightly more intensive than "sedentary work".Flowers appealed this decision, arguing that the ALJ's finding that he could perform "light work" wasn't supported by substantial evidence as there was no proof of his condition improving. He also suggested that the ALJ should have considered the previous finding of him only being able to perform "sedentary work".The United States Court of Appeals for the Eleventh Circuit rejected Flowers' argument. Firstly, the court found that Flowers hadn't raised this legal issue in the lower courts and they declined to consider it for the first time on appeal. Secondly, the court concluded that even if Flowers had raised the issue in the lower courts, any error would have been harmless because Flowers hadn't shown that he would be entitled to disability benefits even if he was limited to "sedentary work". Lastly, the court found that the ALJ's decision was supported by substantial evidence. Consequently, the court affirmed the ALJ's decision. View "Flowers v. Commissioner, Social Security Administration" 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

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

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

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