Justia U.S. 4th Circuit Court of Appeals Opinion Summaries

Articles Posted in Public Benefits
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The Fourth Circuit reversed the district court's decision affirming the ALJ's determination that plaintiff's disability had ceased as of March 31, 2013. The court concluded that the ALJ committed two legal errors: first, the ALJ erred by failing to consider each of the factors listed in 20 C.F.R. 404.1527(c) before affording only negligible weight to the medical opinion of one of plaintiff's treating physicians; and second, the ALJ erred by assessing plaintiff's residual functional capacity (RFC) pursuant to an incorrect framework and without explaining his RFC-related findings in the manner required by Social Security regulations. Accordingly, the court remanded for further administrative proceedings. View "Dowling v. Commissioner of Social Security Administration" on Justia Law

Posted in: Public Benefits
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The Fourth Circuit reversed the district court's order affirming the SSA's denial of plaintiff's application for disability insurance benefits, holding that the ALJ erred by determining that plaintiff was not disabled during the relevant period.The court concluded that the ALJ erred in discrediting plaintiff's subjective complaints by applying the wrong legal standard by effectively requiring plaintiff to provide objective medical evidence of her symptoms; improperly cherry-picking, misstating, and mischaracterizing facts from the record; and drawing various conclusions unsupported by substantial evidence and failing to explain them adequately. Furthermore, the ALJ's decision exhibits a pervasive misunderstanding of fibromyalgia. Applying its discretion to review the issue, the court concluded that the ALJ erred by according little weight to plaintiff's treating physician's opinion. In this case, the ALJ's treatment of the doctor's opinion contains several errors and is not supported by substantial evidence. The court held that the record as a whole clearly establishes plaintiff's disability and thus her legal entitlement to disability benefits. The court remanded to the Commissioner for calculation of disability benefits. View "Arakas v. Commissioner" on Justia Law

Posted in: Public Benefits
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While plaintiffs sought judicial review in federal district court of their denial of Social Security disability benefits, the Supreme Court issued its opinion in Lucia v. Securities and Exchange Commission, 138 S. Ct. 2044 (2018), which elucidated a possible constitutional objection to administrative proceedings pursuant to the Appointments Clause. At issue in this appeal is whether plaintiffs may raise an Appointments Clause challenge in federal court that they did not preserve before the agency.The Fourth Circuit held that claimants for Social Security disability benefits do not forfeit Appointments Clause challenges by failing to raise them during their administrative proceedings. Balancing the individual and institutional interests at play, including considering the nature of the claim presented and the characteristics of the ALJ proceedings, the court declined to impose an exhaustion requirement. Therefore, the court affirmed the judgments of the district courts remanding these cases for new administrative hearings before different, constitutionally appointed ALJs. View "Probst v. Saul" on Justia Law

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The Fourth Circuit affirmed the denial of Social Security disability benefits to plaintiff, who claims that she has been unable to engage in any substantial gainful employment since November 2013, due to a combination of her back and shoulder impairments and a lifelong learning disorder.The court held that the ALJ's findings and the mental limitation included in the residual functional capacity (RFC) are sufficiently explained and supported by substantial evidence in the record. In this case, the ALJ addressed plaintiff's lifelong, borderline intellectual disability, including her moderate limitations in concentration, persistence, or pace; explained why the psychological evidence and plaintiff's statements support a mental limitation to simple, routine, and repetitive tasks; and included the mental limitation in the hypothetical question posed to the vocational expert. The court also held that the ALJ's finding that plaintiff can perform light work despite her physical limitations was supported by substantial evidence in the record. View "Shinaberry v. Saul" on Justia Law

Posted in: Public Benefits
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The Fourth Circuit affirmed the denial of social security disability benefits to plaintiff, holding that there was no conflict between the language describing her residual functioning capacity (RFC) and the DOT's definition of Level 2 reasoning. In this case, the ALJ found that plaintiff could perform jobs limited to simple, routine repetitive tasks of unskilled work. Furthermore, there was no comparable inconsistency between plaintiff's RFC and Level 2's notions of detailed but uninvolved instructions and tasks with a few variables. View "Lawrence v. Saul" on Justia Law

Posted in: Public Benefits
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The Fourth Circuit vacated the district court's decision affirming the denial of plaintiff's application for supplemental security income (SSI). The court held that the ALJ erred by not sufficiently explaining the reasoning underlying plaintiff's residual functional capacity evaluation. Furthermore, the ALJ neither identified nor resolved an apparent conflict between the testimony of a vocational expert and the Dictionary of Occupational Titles. Accordingly, the court remanded for further proceedings. View "Thomas v. Berryhill" on Justia Law

Posted in: Public Benefits
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Nursing Homes, on behalf of eleven residents, filed suit against the Secretaries, alleging that the Secretaries wrongfully denied the residents Medicaid benefits in violation of the Fourteenth Amendment and several federal statutes.The Fourth Circuit affirmed the district court's dismissal of the complaint for lack of subject matter jurisdiction and failure to state a claim. The court held that the Eleventh Amendment barred the Nursing Homes' constitutional and Medicaid Act claims for damages or other relief based on past actions; the Nursing Homes' claims for declaratory and injunctive relief were moot and required dismissal because the court lacked subject matter jurisdiction; and, because the Nursing Homes failed to state a viable Americans with Disabilities Act claim, they failed to state a cognizable Rehabilitation Act claim. View "Wicomico Nursing Home v. Padilla" on Justia Law

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The Fourth Circuit affirmed the district court's grant of summary judgment to the school district in an action under the Individuals with Disabilities Education Act (IDEA), alleging that the school district failed to provide plaintiff, a former student, with a free appropriate public education (FAPE). The court held that the school district committed a procedural violation of the IDEA by failing to respond to parents' requests and conduct a timely evaluation of whether the student was eligible for special education or related services. Nonetheless, plaintiff failed to show that this defect in the process had an adverse effect on his education. Therefore, plaintiff was not actually deprived of a FAPE. View "T.B. v. Prince George's County Board of Education" on Justia Law

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The Fourth Circuit vacated the Social Security Administration's denial of plaintiff's application for disability insurance benefits. The court held that the ALJ erred by not according adequate weight to a prior disability determination by the North Carolina Department of Health and Human Services. Accordingly, the court remanded the case with instructions to vacate the denial of benefits and remanded for further administrative proceedings. View "Woods v. Berryhill" on Justia Law

Posted in: Public Benefits
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The Fourth Circuit vacated the district court's judgment affirming the denial of disability benefits to plaintiff. The court agreed with plaintiff and held that the ALJ improperly assessed the medical opinion evidence and disregarded the treating physician rule in rendering his residual functioning capacity (RFC) determination and finding that plaintiff could persist through an eight-hour workday. Accordingly, the court remanded for further proceedings. View "Brown v. Commissioner Social Security Administration" on Justia Law

Posted in: Public Benefits