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

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

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

Plaintiff challenges the denial of her application for social security disability benefits. Before the court is an issue of first impression regarding whether an ALJ's failure to follow the special technique required by 20 C.F.R. 404.1520a when evaluating a claimant’s mental impairment requires remand or may constitute harmless error. The court held that such an error does not automatically require remand, but that the error was not harmless on these facts. Accordingly, the court reversed the district court's order denying benefits and remanded with instructions to the ALJ for appropriate review of plaintiff's mental impairment. View "Patterson v. Commissioner of SSA" on Justia Law

An ALJ found that Jerry Addison was entitled to benefits under the Black Lung Benefits Act, 30 U.S.C. 901-944, because he had established the existence of clinical and legal pneumoconiosis that resulted in a total respiratory disability. Sea-B, Addison's former employer, filed a petition for review of the ALJ's decision. The court concluded that the ALJ’s decision to exclude the additional CT scan evidence was not harmless. This error affects the determination of both clinical and legal pneumoconiosis and impacts the ALJ’s consideration of the other evidence in this case. The omitted CT scan evidence is unquestionably probative of the central issue in dispute: whether Addison suffered from pneumoconiosis. Furthermore, the court could not determine from the ALJ’s sparse explanation how, or if, he weighed the x-ray readings in light of the readers’ qualifications. Finally, because the proffered explanation for elevating Dr. Forehand’s diagnosis is not supported, the ALJ must reevaluate that opinion to determine the proper weight it should be given. Accordingly, the court granted the petition for review, vacated the order, and remanded for further proceedings. View "Sea "B" Mining Co. v. Addison" on Justia Law

Relators filed suit against medical laboratory businesses in 2007 in state court, alleging that the labs had submitted false claims to the Commonwealth for Medicaid reimbursement. Defendants removed to federal court. After the Commonwealth entered into a settlement agreement with defendants, the district court awarded relators a share of the settlement proceeds. Relators appealed, contending that the district court's award was insufficient under state law. The court vacated and remanded to the state court, concluding that the district court lacked subject matter jurisdiction over the qui tam action. In this case, by the plain terms of the complaint, relators could have prevailed on their state law claims by proving that defendants contravened the Commonwealth’s Medicaid regulations, without showing any violation of federal law. View "Commonwealth of Virginia ex rel. Hunter Labs. v. Commonwealth of Virginia" on Justia Law

Plaintiff appealed the denial of his applications for disability insurance benefits (DIB) and supplemental security income (SSI). Plaintiff sought disability benefits, alleging disability beginning December 8, 2006, due to uveitis; back pain, breathing and memory problems; anxiety; depression; and blackouts. The court reversed and remanded, concluding that the ALJ erred by not conducting a function-by-function analysis of plaintiff's limitations and by not adequately explaining his decision. View "Monroe v. Colvin" on Justia Law

The Hospital system filed suit seeking to obtain a writ of mandamus compelling HHS to adjudicate immediately its administrative appeals on claims for Medicare reimbursement. The parties agree that, as of February 2014, the Secretary had 480,000 appeals awaiting assignment to an ALJ, and the Secretary conceded in her brief that the number had by then climbed to more than 800,000 appeals, creating a ten-year backlog. The court concluded that the Medicare Act, 42 U.S.C. 1395 et seq., does not guarantee a healthcare provider a hearing before an ALJ within 90 days, as the Hospital System claims. Rather, it provides a comprehensive administrative process that a healthcare provider must exhaust before ultimately obtaining review in a United States district court. The court further concluded that the issuance of a judicial order now, however, directing the Secretary to hear the Hospital System’s claims in the middle of the administrative process, would unduly interfere with the process and, at a larger scale, the work of the political branches. Moreover, such intervention would invite other healthcare providers suffering similar delays to likewise seek a mandamus order, thereby effectively causing the judicial process to replace and distort the agency process. Accordingly, the court affirmed the district court's dismissal of the complaint. View "Cumberland Cnty. Hosp. v. Burwell" on Justia Law

Plaintiff appealed the denial of his application for Social Security disability benefits, contending that the ALJ failed to resolve a conflict between the vocational expert's testimony and the Dictionary of Occupational Titles. The court held that an ALJ has not fully developed the record if it contains an unresolved conflict between the expert’s testimony and the Dictionary; nor has the ALJ fulfilled this duty if he ignores an apparent conflict because the expert testified that no conflict existed. In this case, the ALJ did not fulfill his duty to make an independent identification of apparent conflicts. Accordingly, the court reversed and remanded for further proceedings. View "Pearson v. Colvin" on Justia Law

Bonnilyn Mascio filed an application with the Social Security Administration for supplemental security income benefits, alleging that she was disabled from degenerative disc disease, carpal tunnel syndrome, and adjustment disorder. An administrative law judge (ALJ) found that Mascio was not disabled. The district court reversed. On remand, a second ALJ found that Mascio was not disabled and denied her application. The district court upheld the denial of benefits. The Fourth Circuit reversed, holding that the ALJ erred (1) in assessing Mascio’s residual functional capacity because he did not conduct a function-by-function analysis; (2) by not considering Mascio’s moderate limitation in her ability to maintain her concentration, persistence, or pace; and (3) by determining Mascio’s residual functional capacity before assessing her credibility. Remanded. View "Mascio v. Colvin" on Justia Law

Plaintiffs, parents of nine-year-old E.L., who has autism, initiated an administrative complaint against the school board under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. An ALJ determined that the school board violated the IDEA by failing to provide E.L. with required speech therapy but, in all other respects, she was provided an appropriate special education program. The school board appealed and the state review officer reversed the ALJ's conclusion regarding the speech therapy. Plaintiffs then filed a civil action seeking judicial review of the administrative proceedings. The court concluded that E.L. did not exhaust her administrative remedies and that the school board did not violate the IDEA where the review officer's conclusion that E.L. received the speech therapy mandated by her individualized education program is supported by the evidence. Accordingly, the court affirmed the judgment. View "E. L. v. Chapel Hill-Carrboro Board of Education" on Justia Law