Justia U.S. 6th Circuit Court of Appeals Opinion Summaries

Paula S. Linden applied for Social Security benefits online in September 2014 at the age of 62, which was before her full retirement age of 66. As a result, she received smaller monthly payments than she would have if she had waited until 66. Linden claimed that she applied early based on misinformation from the Social Security Administration (SSA), which allegedly told her that she would receive the same benefits as if she had applied at 66. She sought to have her benefits recalculated as if she had applied at 66.The SSA denied her request, both initially and upon reconsideration. An Administrative Law Judge (ALJ) also ruled against her, stating that the statutory provision she cited, 42 U.S.C. § 402(j)(5), only applied to individuals who failed to apply for benefits due to misinformation. The ALJ also found insufficient evidence that Linden received misinformation from the SSA. The Appeals Council denied her request for review. Linden then filed a complaint in the United States District Court for the Eastern District of Michigan, which granted summary judgment in favor of the SSA and denied Linden’s motion for summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the plain text of 42 U.S.C. § 402(j)(5) precluded Linden’s recovery because the statute only applies to individuals who failed to apply for benefits due to misinformation. Since Linden did apply for benefits, she did not meet the statutory requirement. The court also found that the SSA’s regulations supported this interpretation. Additionally, the court noted that even if there was misinformation, it would not change the outcome because Linden did not fail to apply for benefits. Therefore, the court affirmed the district court’s decision. View "Linden v. Comm'r of Soc. Sec." on Justia Law

Ken Lick Coal Company employed Bob Reed from 1973 to 1986, during which he was exposed to coal dust. Reed later worked for Green Valley Hydro Seeding & Reclamation and JPR, where he continued to be exposed to coal dust. Reed developed breathing problems and filed three claims for black-lung benefits. His first claim in 1986 was denied. His second claim in 2007 was initially granted but later denied by an administrative law judge who found Reed did not have pneumoconiosis. Reed's third claim in 2018 was pursued by his widow after his death.The district director awarded benefits and designated Ken Lick as the responsible operator. An administrative law judge upheld this decision, finding Reed had over 15 years of coal-mine employment, including his work with Green Valley and JPR. The judge also found that Ken Lick had stipulated to being the responsible operator during Reed's second claim, which the judge deemed binding in the third claim.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the administrative law judge erred in treating Ken Lick's prior stipulation as binding. The court found that the stipulation was a legal conclusion rather than a factual one, and thus, the judge had the authority to disregard it. The court noted that the administrative law judge would not have required Ken Lick to pay the benefits but for the stipulation. Consequently, the Sixth Circuit granted Ken Lick's petition for review and transferred the liability for Reed's claim to the Black Lung Disability Trust Fund. View "Ken Lick Coal Co. v. OWCP" on Justia Law

Donald Hunter, a former coal miner, applied for benefits under the Black Lung Benefits Act (BLBA) in 2019, claiming that he was totally disabled due to chronic obstructive pulmonary disease (COPD) caused by his coal mine employment. Southern Ohio Coal Company, his former employer, contested his claim, arguing that Hunter's COPD was caused by his significant history of smoking cigarettes rather than coal mine dust exposure.An Administrative Law Judge (ALJ) reviewed the case and awarded benefits to Hunter, finding that his COPD constituted legal pneumoconiosis and that it was a substantially contributing cause of his total disability. Southern Ohio Coal appealed to the Benefits Review Board (BRB), arguing that the ALJ erred in discrediting its evidence and in crediting Hunter's evidence. The BRB affirmed the ALJ's decision, holding that the ALJ had properly considered and weighed the evidence.The United States Court of Appeals for the Sixth Circuit reviewed the case. Southern Ohio Coal argued that the ALJ erred by relying on a pulmonary function test (PFT) that did not comply with regulatory quality standards and by relieving Hunter of his burden to establish entitlement to benefits. The court found that the ALJ acted within his discretion in determining that the PFT was compliant and supported Hunter's entitlement to benefits. The court also held that the ALJ did not improperly rely on regulatory guidance or flip the burden of proof to Southern Ohio Coal. The ALJ's decision was supported by substantial evidence, including expert opinions and Hunter's testimony.The Sixth Circuit denied the petition for review, affirming the ALJ's decision to award benefits to Hunter. The court held that the ALJ correctly applied the law and that his decision was supported by substantial evidence. View "Southern Ohio Coal Co. v. Office of Workers' Compensation Programs" on Justia Law

Edna Napier, a former cashier and certified nursing assistant, applied for disability insurance benefits due to severe physical conditions and mental impairments, including depression and anxiety. Her initial application was denied by the Social Security Administration (SSA) in 2018. Napier filed a new application in December 2019, claiming she had been unable to work since December 2018. An administrative law judge (ALJ) held an evidentiary hearing and concluded that Napier was not disabled under the Social Security Act, finding that her mental impairments were mild and her physical impairments did not prevent her from performing her past work as a cashier.The United States District Court for the Eastern District of Kentucky affirmed the ALJ's decision. Napier appealed, arguing that the ALJ erred in assessing the severity of her mental impairments and failed to account for them in her residual functional capacity (RFC) analysis.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the ALJ's decision was supported by substantial evidence and complied with proper legal standards. The ALJ had considered Napier's testimony, her limited treatment history for mental impairments, and the opinions of several psychologists. The ALJ found that Napier's mental impairments were not severe and that her physical impairments did not preclude her from performing her past work. The court also found that the ALJ adequately accounted for Napier's mental impairments in the RFC analysis.The Sixth Circuit affirmed the district court's judgment, concluding that the ALJ's findings were supported by substantial evidence and that the ALJ had followed the appropriate procedures in evaluating Napier's claims. View "Napier v. Commissioner of Social Security" on Justia Law

Joseph Fortin applied for disability insurance benefits, but his claim was denied by an Administrative Law Judge (ALJ) from the Social Security Administration (SSA). Fortin argued that the ALJ who denied his claim was improperly appointed because the then-Acting Commissioner of the SSA, Nancy Berryhill, lacked the authority to ratify the ALJ's appointment. Fortin did not challenge the merits of the ALJ's decision but focused on the validity of the ALJ's appointment.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the Commissioner of Social Security, rejecting Fortin's arguments. The court held that Berryhill's ratification of the ALJ's appointment was valid and that the ALJ did not err in denying Fortin's application for benefits.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Berryhill, as Acting Commissioner, had the authority to ratify the appointments of SSA ALJs in response to the Supreme Court's decision in Lucia v. Securities and Exchange Commission, which required ALJs to be appointed in accordance with the Appointments Clause. The court also concluded that Berryhill's actions were valid under the Federal Vacancies Reform Act and that she did not need to be reappointed by the sitting President to serve as Acting Commissioner. The court found that Berryhill's ratification of the ALJ's appointment was both constitutionally and statutorily valid, and therefore, Fortin was not entitled to a new hearing before a different ALJ. View "Fortin v. Commissioner of Social Security" on Justia Law

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

Adams, born in 1960, smoked about a pack a day starting at age 18 and worked in coal mines at times between 1979-1995, mostly underground using a “cutting machine” in the “dustiest” areas. Adams struggled to breathe after his retirement. Adams’s 1998 application under the Black Lung Benefits Act, 30 U.S.C. 901(b), was denied because he failed to prove that he had pneumoconiosis. In 2008, Adams sought benefits from Wilgar. His treating physician, Dr. Alam, identified the causes of his 2013 death as cardiopulmonary arrest, emphysema, coal worker’s pneumoconiosis, throat cancer, and aspiration pneumonia.A 2019 notice in the case stated “the Court may look to the preamble to the revised” regulations in weighing conflicting medical opinions. Wilgar unsuccessfully requested discovery concerning the preamble and the scientific studies that supported its conclusions. The ALJ awarded benefits, finding that Adams had “legal pneumoconiosis” and giving Dr. Alam’s opinion that Adam’s coal mine work had substantially aggravated his disease “controlling weight.” All things being equal, a treating physician’s opinion is “entitled to more weight,” 30 C.F.R. 718.104(d)(1). Wilgar's three experts had opined that Adams’s smoking exclusively caused his disease The ALJ gave “little weight” to these opinions, believing that they conflicted with the preamble to the 2001 regulation.The Benefits Review Board and Sixth Circuit affirmed. The preamble interpreted the then-existing scientific studies to establish that coal mine work can cause obstructive diseases, either alone or in combination with smoking. The ALJ simply found the preamble more persuasive than the experts. View "Wilgar Land Co. v. Director, Office of Workers’ Compensation Programs" on Justia Law

Waters was born with homocystinuria and diagnosed with that condition at the age of six. Homocystinuria is a genetic attribute that causes metabolic issues that prevent Waters’s liver from metabolizing methionine, an amino acid, that produces L-cysteine, another amino acid. Her physician prescribed HCU coolers–a medical food containing a methionine-free protein formula. Waters ingests HCU coolers orally; she has a fully functioning gastrointestinal tract. Waters sought reimbursement for HCU coolers purchased during 2018-2019, under the prosthetic-device benefit of Medicare Part B, 42 U.S.C. 1395k(a)(2)(I); 1395x(s)(8). The National Coverage Determinations Manual explains that, as part of the prosthetic-device benefit, enteral nutrition is considered reasonable and necessary when a patient “cannot maintain weight and strength commensurate with his” “general condition” because food does not reach the digestive tract and specifies that “[e]nteral therapy may be given by nasogastric [nose], jejunostomy [small intestine], or gastrostomy [stomach] tubes.” The NCD acknowledges “[s]ome patients require supplementation of their daily protein and caloric intake,” but “[n]utritional supplementation is not covered under Medicare Part B.”The Sixth Circuit affirmed several levels of denial of Waters’s claim, acknowledging the difficult circumstances of Waters and her family. An HCU cooler is not a stand-alone prosthetic device based on the plain meaning of prosthetic “device” and because an HCU cooler is a medical food according to the FDA. View "Waters v. Becerra" on Justia Law

Out-of-work residents of Michigan may claim unemployment benefits if they meet certain eligibility criteria. The State’s Unemployment Insurance Agency oversees the benefits system. In 2011, with the help of private contractors, the Agency began to develop software to administer the unemployment system. The Agency sought to equip the software to auto-adjudicate as many parts of the claims process as possible. The Agency programmed software that used logic trees to help process cases and identify fraud. A claimant’s failure to return the fact-finding questionnaire, for example, led to a fraud finding, as did the claimant’s selection of certain multiple-choice responses. In August 2015, problems arose with some features of the system, prompting the Agency to turn off the auto-adjudication feature for fraud claims.Plaintiffs are four individuals who obtained unemployment benefits, which were terminated after the Agency flagged their claims for fraud. Plaintiffs filed a putative class action against three government contractors and nineteen Agency staffers, raising claims under the Fourth, Fifth, and Fourteenth Amendments, 26 U.S.C. Sec. 6402(f), and Michigan tort law. In a previous proceeding, the court held that plaintiffs’ due process rights clearly existed because they had alleged a deprivation of their property interests without adequate notice and without an opportunity for a pre-deprivation hearing.At this stage, because the remaining plaintiffs have failed to show that these procedures violate any clearly established law, the supervisors of the unemployment insurance agency are entitled to judgment as a matter of law. The court also found that an intervening plaintiff was properly prevented from joining the case, based on her untimely filing. View "Patti Cahoo v. SAS Institute, Inc." on Justia Law

Child foster care systems in this country are administered by state governments. The federal government reimburses states for “foster care maintenance payments” that the state makes to certified foster caregivers who meet federal-eligibility requirements. In Ohio, there are also foster caregivers (typically relatives) whom the state does not certify as meeting those federal requirements. Ohio withholds payments for those caregivers and provides these non-certified caregivers with less generous payments through a separate state program. The plaintiffs, foster caregivers whom Ohio has considered ineligible to receive the higher foster care maintenance payments, sued. The district court dismissed, finding that the caregivers did not have to meet the same licensing standards as licensed caregivers in Ohio and thus were not “foster family homes” as required by federal law.The Sixth Circuit affirmed. Title IV-E of the Social Security Act, 42 U.S.C. 671 (a), requires that all foster family homes eligible for payments under federal law meet the same licensing standards; the plaintiffs are subject to different standards than “licensed” caregivers are not “foster family home,” and are not eligible for the higher payments. View "T.M. v. DeWine" on Justia Law