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

Articles 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
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Plaintiff appealed the denial of her application for disability insurance benefits and supplemental security income. The Fourth Circuit held that the ALJ did not give appropriate weight to the opinions of plaintiff's treating physicians and failed to adequately explain his decision to deny her benefits. Accordingly, the court vacated and remanded for further proceedings. View "Lewis v. Berryhill" on Justia Law

Posted in: Public Benefits
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Social security survivors' benefits are a thing of value of the United States that can support a conviction under 18 U.S.C. 641. Viewed in the light most favorable to the government, the Fourth Circuit concluded that substantial evidence supported defendant's conviction for theft of government property beyond a reasonable doubt. In this case, the jury could reasonably infer from two denied benefits applications that defendant had a motive to file under a different benefits program to again attempt to obtain benefits to which he was not entitled. Finally, the district court's trial management was reasonable and far from an abuse of discretion. Accordingly, the court affirmed the judgment. View "United States v. Kiza" on Justia Law