Justia U.S. 11th Circuit Court of Appeals Opinion Summaries

An employee worked for Cowin & Company for nearly three decades, performing construction in coal mines and regularly being exposed to coal dust. Years after his employment ended, he filed a claim for benefits under the Black Lung Benefits Act, alleging total disability due to pneumoconiosis (“black lung disease”) caused by his coal mine work. The claimant relied on a regulatory presumption that applies to miners who have a disabling breathing impairment and at least fifteen years of qualifying coal mine employment. A key dispute in the case involved how to calculate a “year” of coal mine employment under Department of Labor regulations.An administrative law judge initially granted benefits, finding the claimant had at least fifteen years of qualifying employment, thus triggering the presumption. Cowin & Company appealed to the Benefits Review Board, which vacated the benefits award in part and instructed the judge to recalculate the length of coal mine employment, questioning the method used to credit years of employment. On remand, the judge again found more than fifteen years, but the Board disagreed with the method, holding that a claimant must prove both a 365/366-day period of employment and at least 125 working days during that period. Ultimately, after further proceedings, the administrative law judge found only 13.76 years of qualifying employment, and the Board affirmed the denial of benefits.The United States Court of Appeals for the Eleventh Circuit reviewed the Board’s decision. The court held that, under the plain text of the relevant regulation, a claimant establishes a “year” of coal mine employment by showing at least 125 working days in or around coal mines during a calendar year or partial periods totaling one year. The court granted the petition for review, vacated the Board’s decision, and remanded for further proceedings. View "Hayes v. Director, OWCP" on Justia Law

The United States brought a lawsuit against Florida alleging that the state was discriminating against children with medically complex conditions by failing to provide care in the most integrated setting as required under Title II of the Americans with Disabilities Act (ADA). The federal government claimed that Florida’s inadequate provision of at-home and group-home care forced some children into institutionalization and placed others at serious risk of institutionalization. Additionally, it argued that once children were institutionalized, Florida’s poor care coordination and deficient transition planning made it difficult for families to bring their children home.This litigation proceeded over many years, culminating in a bench trial in the United States District Court for the Southern District of Florida. Previously, the United States Court of Appeals for the Eleventh Circuit had determined that the United States had statutory authority to sue Florida under the ADA. After trial, the district court found that Florida’s Medicaid program failed to provide adequate private duty nursing (PDN) services and effective care coordination, resulting in unnecessary institutionalization of children or placing them at risk. The district court concluded that these failures constituted violations of the ADA as interpreted by Olmstead v. L.C. ex rel Zimring, and issued a permanent injunction requiring Florida to improve its services, with specific mandates regarding PDN, care coordination, transition planning, data collection, and appointment of a monitor.On appeal to the United States Court of Appeals for the Eleventh Circuit, Florida challenged the findings and scope of the injunction. The Eleventh Circuit held that the United States may seek injunctive relief for systemic ADA violations affecting a group of children, not just those who individually filed complaints. The court affirmed the district court’s findings that the United States established the elements required under Olmstead, that the violations were widespread, and that system-wide injunctive relief was warranted. The Eleventh Circuit affirmed the district court’s liability determinations and most provisions of the injunction, but vacated or modified some portions as overbroad. View "United States v. Florida" on Justia Law

Florida challenged a federal agency document known as the “Informational Bulletin” that interpreted Medicaid’s hold-harmless rule and threatened to claw back billions in Medicaid funds if certain state practices continued. Florida’s Medicaid funding system relies on a Directed Payment Program, under which local governments assess special fees on private hospitals, pool these fees, and transfer the funds to the state agency, which then uses them to secure additional federal matching funds. The state feared the new federal interpretation could jeopardize its program and moved to preliminarily enjoin the Bulletin’s implementation.The United States District Court for the Southern District of Florida, following a magistrate judge’s recommendation, denied Florida’s motion for a preliminary injunction and dismissed the case for lack of subject matter jurisdiction. The district court held that the Bulletin was not a “final agency action” under the Administrative Procedure Act (APA), and therefore not subject to judicial review.The United States Court of Appeals for the Eleventh Circuit reviewed the case and found that, contrary to the district court’s conclusion, the Bulletin was indeed a final agency action subject to judicial review under the APA. However, the Eleventh Circuit held that Florida was unlikely to succeed on the merits of its challenge, concluding that the Bulletin’s interpretation of the Medicaid hold-harmless rule was consistent with the statutory text, was not arbitrary or capricious, and did not require notice-and-comment rulemaking. The court thus reversed the dismissal of the complaint, affirmed the denial of the preliminary injunction, and remanded the case for further proceedings. View "Florida Agency for Health Care Administration v. Administrator for the Centers for Medicare & Medicaid Services" on Justia Law

An Army veteran serving a lengthy prison sentence in Florida applied for and received disability benefits for service-related post-traumatic stress disorder. Initially, the Veterans Benefits Administration approved his claim at a 70 percent rate, later increasing it to 80 percent. However, after his felony conviction and incarceration, the Administration reduced his monthly benefits to a 10 percent rate pursuant to 38 U.S.C. § 5313, which limits disability payments for veterans incarcerated for more than 60 days due to a felony.The veteran filed a pro se complaint in the United States District Court for the Middle District of Florida, naming the United States Congress as defendant. He alleged that the statute reducing his benefits violated the Bill of Attainder Clause and the Equal Protection component of the Fifth Amendment, seeking both prospective and retroactive relief. A magistrate judge recommended dismissal, assuming without deciding that the court had jurisdiction over facial constitutional challenges, but finding the claims frivolous. The district court adopted this recommendation, dismissing the complaint and declining to address the plaintiff’s general objections.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that sovereign immunity barred the suit against Congress, as Congress has not waived immunity for constitutional claims arising from its enactment of legislation. The court further held that any amendment to name a different defendant would be futile because the Veterans’ Judicial Review Act provides an exclusive review scheme for challenges to veterans’ benefits decisions, channeling all such claims—including constitutional challenges—through the administrative process and ultimately to the Court of Appeals for Veterans Claims and the Federal Circuit. The Eleventh Circuit vacated the district court’s judgment and remanded with instructions to dismiss the case without prejudice for lack of jurisdiction. View "Johnson v. United States Congress" on Justia Law

Rachael Gorecki applied for disability benefits and received a hearing before an administrative law judge (ALJ) whose appointment was ratified by Nancy Berryhill during her second tenure as Acting Commissioner of the Social Security Administration. The ALJ denied Gorecki's benefits application, and the Social Security Administration's Appeals Council denied review, making the decision final. Gorecki then sued, arguing that the ALJ had no constitutional authority to issue a decision because Berryhill's second stint as Acting Commissioner violated the Federal Vacancies Reform Act (FVRA).The United States District Court for the Northern District of Alabama rejected Gorecki's argument, aligning with other appellate courts that had ruled on similar issues. The district court found that Berryhill's second tenure as Acting Commissioner was lawful under the FVRA.The United States Court of Appeals for the Eleventh Circuit reviewed the case and joined five other circuits in holding that the FVRA authorized Berryhill's second stint as Acting Commissioner. The court found that the plain text of the FVRA allowed Berryhill to serve again as Acting Commissioner once a nomination for the office was submitted to the Senate, regardless of whether the nomination occurred during the initial 210-day period. The court affirmed the district court's judgment, concluding that Berryhill's ratification of the ALJ's appointment was valid and that the ALJ had the authority to deny Gorecki's benefits application. The Eleventh Circuit thus affirmed the lower court's decision. View "Gorecki v. Commissioner, Social Security Administration" on Justia Law

The plaintiff, Afaf Beshay Malak, applied for disability insurance benefits (DIB) in 2021, citing several disabilities including pinched nerves, osteoarthritis, fibromyalgia, and chronic headaches. Her application was denied initially and upon reconsideration by disability examiners. Malak then had a hearing before an Administrative Law Judge (ALJ), who followed the five-step evaluation process for disability claims. The ALJ determined that Malak had severe impairments but did not meet the criteria for a listed impairment. The ALJ assessed Malak’s Residual Functional Capacity (RFC) and found she could perform sedentary work with certain limitations. The ALJ concluded that Malak could perform her past work as a financial institution manager and other jobs in the national economy, thus finding her not disabled.Malak appealed the ALJ’s decision to the Appeals Council, which denied her request for review, making the ALJ’s decision the final decision of the Commissioner of Social Security. Malak then appealed to the district court, which affirmed the ALJ’s denial of her DIB claim. Malak subsequently appealed to the United States Court of Appeals for the Eleventh Circuit.The Eleventh Circuit reviewed the case to determine if the ALJ’s decision was supported by substantial evidence. Malak argued that the ALJ failed to consider her medically related absences and the side effects of her treatments. The court held that the ALJ is not required to consider the time needed for medical appointments when determining RFC, as RFC assessments focus on functional limitations caused by medically determinable impairments. The court also found that the ALJ properly considered the effectiveness and side effects of Malak’s treatments, noting that the medical evidence showed positive responses to treatments without significant side effects. The Eleventh Circuit affirmed the district court’s decision, upholding the denial of Malak’s DIB claim. View "Malak v. Commissioner of Social Security" on Justia Law

A former railroad employee, Demetris Hill, was convicted of theft of government property and making a false claim to the Railroad Retirement Board (RRB). Hill had been receiving monthly disability benefits from the RRB since 2012, based on his claim that he was unable to perform substantial gainful activity. As a condition of receiving these benefits, Hill was required to report any changes in his employment status, including any ownership in a family business. Despite this, Hill helped his ex-wife start a janitorial business, SparClean Premier Cleaning Solutions, and failed to report his involvement to the RRB.Hill was initially charged in a 60-count indictment for theft of government money or property. A superseding indictment later charged him with one count of theft of government property, one count of making false claims to the government, and one count of wire fraud. After a jury trial, Hill was found guilty of theft of government property and making false claims but was acquitted of wire fraud. The district court denied Hill’s motion for judgment of acquittal and sentenced him to 33 months for each conviction, to be served concurrently, followed by supervised release. Hill appealed his convictions.The United States Court of Appeals for the Eleventh Circuit reviewed Hill’s appeal. The court found sufficient evidence that Hill was not entitled to the disability payments because he engaged in substantial gainful activity and failed to report his involvement with SparClean. The court also found that Hill knowingly deprived the government of its property by continuing to receive the payments without reporting his employment status. Additionally, the court held that receiving direct deposits while failing to disclose his employment constituted making a false claim to the government. Hill’s arguments regarding the sufficiency of evidence, the jury instruction, and the constitutionality of the False Claims Act were rejected. The Eleventh Circuit affirmed Hill’s convictions. View "USA v. Hill" on Justia Law

The case involves Bradley Rodriguez, who applied for disability benefits and supplemental security income, claiming a disability due to a traumatic brain injury, bipolar disorder, and depression. His application was denied by an Administrative Law Judge (ALJ) with the Social Security Administration (SSA). The Appeals Council also denied his request for review. Rodriguez then filed a federal lawsuit challenging the denial of benefits, raising several constitutional issues regarding the appointment of SSA ALJs, Appeals Council members, and the Commissioner of the SSA. He also argued that the ALJ’s decision was not supported by substantial evidence.The United States District Court for the Southern District of Florida granted summary judgment in favor of the Commissioner of the SSA. The court found that the ALJ was properly appointed, the Appeals Council members were not principal officers requiring presidential appointment and Senate confirmation, and the for-cause removal provision for the Commissioner was unconstitutional but severable. The court also held that Rodriguez was not entitled to a new hearing because he did not show that the unconstitutional removal provision caused him any harm. Additionally, the court determined that the ALJ’s decision was supported by substantial evidence.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The court held that the Commissioner had the statutory authority to appoint SSA ALJs and properly exercised that authority through ratification in July 2018. The Appeals Council members were deemed inferior officers, not principal officers, and thus did not require presidential appointment and Senate confirmation. The court also agreed that the for-cause removal provision for the Commissioner was unconstitutional but severable, and Rodriguez did not demonstrate entitlement to retrospective relief. Finally, the court found that the ALJ’s decision was supported by substantial evidence, including medical records and vocational expert testimony. View "Rodriguez v. Social Security Administration" on Justia Law

The case involves a class action lawsuit brought by several minor children, through their legal guardians, against the Commissioner of the Georgia Department of Community Health. The plaintiffs challenged the Department's practices regarding the provision of skilled nursing services under the Medicaid Act. Specifically, they contested the Department's use of a scoresheet to determine the number of skilled nursing hours and the practice of reducing those hours as caregivers learn to perform skilled tasks.The United States District Court for the Northern District of Georgia granted summary judgment in favor of the plaintiffs. The court ruled that the Department's review process did not give appropriate weight to the recommendations of treating physicians and that the practice of reducing skilled nursing hours as caregivers learn skilled tasks violated the Medicaid Act. The district court issued permanent injunctions requiring the Department to approve the skilled nursing hours prescribed by the patients' treating physicians.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court's decision. The appellate court held that the Department's review process, which includes the use of a scoresheet to determine a presumptive range of skilled nursing hours, complies with the Medicaid Act. The court also found that the practice of reducing skilled nursing hours as caregivers learn skilled tasks is reasonable and does not violate the Act. The court vacated the permanent injunctions and remanded the case for further proceedings. The appellate court did not address the plaintiffs' challenge regarding the consideration of caregiver capacity, as the district court had ruled that issue moot. The appeal of the preliminary injunctions was deemed moot following the vacatur of the permanent injunctions. View "M.H. v. Commissioner, Georgia Dept. of Community Health" on Justia Law

The case involves a claimant, Isaac Flowers, who applied for Social Security Disability benefits due to various health issues including back, neck, shoulder, and joint problems, obesity, vision loss in one eye, and depression and opioid dependence. The Administrative Law Judge (ALJ) initially denied his claim, deeming that he could perform "sedentary work". Later, Flowers applied for benefits again, and the ALJ denied his claim again, this time finding that he could perform "light work", a classification slightly more intensive than "sedentary work".Flowers appealed this decision, arguing that the ALJ's finding that he could perform "light work" wasn't supported by substantial evidence as there was no proof of his condition improving. He also suggested that the ALJ should have considered the previous finding of him only being able to perform "sedentary work".The United States Court of Appeals for the Eleventh Circuit rejected Flowers' argument. Firstly, the court found that Flowers hadn't raised this legal issue in the lower courts and they declined to consider it for the first time on appeal. Secondly, the court concluded that even if Flowers had raised the issue in the lower courts, any error would have been harmless because Flowers hadn't shown that he would be entitled to disability benefits even if he was limited to "sedentary work". Lastly, the court found that the ALJ's decision was supported by substantial evidence. Consequently, the court affirmed the ALJ's decision. View "Flowers v. Commissioner, Social Security Administration" on Justia Law