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

The Montgomery County Council established the Emergency Assistance Relief Payment Program (EARP) in March 2020 to provide emergency cash assistance to County residents with incomes equal to or less than 50% of the federal poverty benchmark who were not eligible for federal or state pandemic relief. Although eligibility for EARP aid is not dependent on a person’s status as an undocumented immigrant, such individuals are eligible to receive EARP payments. To fund EARP, the County appropriated $10,000,000 from reserve funds to the County’s Department of Health and Human Services. Taxpayers filed suit in Maryland state court, asserting that EARP violated 8 U.S.C. 1621(a), which, with few exceptions, generally prohibits undocumented persons from receiving state and local benefits. Recognizing that Section 1621 does not authorize private enforcement, the plaintiffs cited the Maryland common law doctrine of taxpayer standing, which “permits taxpayers to seek the aid of courts, exercising equity powers, to enjoin illegal and ultra vires acts of [Maryland] public officials where those acts are reasonably likely to result in pecuniary loss to the taxpayer.” The case was removed to federal court based on federal question jurisdiction, 28 U.S.C. 1331. The court granted the County summary judgment. The Fourth Circuit affirmed. Congress has declined to authorize private parties to enforce Section 1621, a legislative decision that cannot be circumvented by invocation of a state’s law of taxpayer standing. View "Bauer v. Elrich" on Justia Law

Plaintiffs, former recipients of Social Security disability benefits and former clients of an attorney who orchestrated one of the largest fraud schemes in the history of the SSA, argued in consolidated appeals that SSA's categorical exclusion of allegedly fraudulent medical evidence during the redetermination process was unlawful because they were never afforded any opportunity to rebut the allegation that their evidence was tainted by fraud.The Fourth Circuit joined its sister circuits and held that the SSA's redetermination procedures violate the Administrative Procedure Act (APA) and the Due Process Clause of the Fifth Amendment. The court agreed with plaintiffs that it is arbitrary and capricious for the agency to deny beneficiaries an opportunity to contest the Office of the Inspector General's fraud allegations as to their cases, while permitting other similarly situated beneficiaries to challenge similar allegations arising from SSA's own investigations. The court also agreed with plaintiffs that the SSA's redetermination procedures violated their due process rights under the Fifth Amendment because they were denied the opportunity to contest the Office of the Inspector General's fraud allegations against them. In this case, the court considered each Mathews factor and concluded that each factor supports a finding that the SSA's redetermination procedures violated plaintiffs' due process rights. Accordingly, the court affirmed in No. 19-1989 and reversed in No. 19-2028. View "Kirk v. Commissioner of Social Security Administration" on Justia Law

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

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

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

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

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

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

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

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