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

Plaintiff appealed the denial of his application for disability insurance benefits and supplemental security income. The court held that the Appeals Council committed legal error when it failed to consider materials from a psychologist who examined plaintiff. Accordingly, the court reversed and remanded with instructions. View "Washington v. SSA" on Justia Law

Plaintiff appealed the denial of his application for disability insurance benefits and supplementary security income, arguing that the ALJ erred in refusing to give proper weight to the opinion of a consultative examining physician, and in finding that plaintiff's 2012 testimony was not credible and failing to consider his vision limitations when evaluating his residual functioning capacity. The court agreed that the ALJ erred in both respects and reversed the judgment of the district court, remanding for further proceedings. View "Henry v. Commissioner" on Justia Law

Petitioner Rachel Parks appealed an administrative law judge's denial of her application for supplemental security income on behalf of her minor son, D.P. D.P. suffered from attention deficit hyperactivity disorder and borderline intellectual functioning. An administrative law judge denied Parks’s application because D.P. did not suffer from a condition that entitled him to supplemental security income. Parks filed a request for review with the Appeals Council, and she submitted new evidence of D.P.’s academic struggles. The Appeals Council supplemented the record with the new evidence, but denied review. Parks then filed a complaint in the district court, which affirmed the denial of her application. She argued on appeal to the Eleventh Circuit: (1) the administrative law judge's denial of Parks's application was not supported by substantial evidence; and (2) the Social Security Appeals Council needed to make explicit findings of fact about new evidence that it added to the record when it denied review. Because the administrative law judge’s decision was supported by substantial evidence and the Appeals Council was not required to make specific findings about Parks’s new evidence, the Eleventh Circuit affirmed. View "Parks v. Commissioner, Social Security Administration" on Justia Law

Pursuant to written plea agreements, defendants Yolanda Sosa and Adrian Velazquez pled guilty to conspiracy to commit healthcare fraud. For a five month period in 2011, Defendants met with a "cooperating doctor" and paid the doctor for prescriptions that Defendants could use to fraudulently bill Medicare. Specifically, Defendants provided the cooperating doctor with Medicare beneficiary information and paid the doctor thousands of dollars to write prescriptions for expensive medications that were not actually given to any patients. The doctor never saw or evaluated the patients, and instead wrote the prescriptions for whatever medications Defendants requested. Defendants gave the fraudulent prescriptions to various pharmacies, which submitted false claims to Medicare based on the prescriptions. As a result, Medicare paid the pharmacies approximately $753,430 based on the false claims. The pharmacies paid Defendants over $60,000 for obtaining the fraudulent prescriptions. Defendants appealed two forfeiture orders entered by the district court after it imposed joint-and-several restitution against them, specifically challenging the restitution amount and the forfeiture of two cars. After careful review of the record and the parties' briefs, and with the benefit of oral argument, the Eleventh Circuit found no reversible error and affirmed the district court. View "United States v. Velazquez" on Justia Law

Plaintiff appealed the denial of his application for supplemental security income (SSI). The court concluded that substantial evidence supported the ALJ's decision denying plaintiff's application for SSI where the ALJ's decision in this case was not a broad rejection and was sufficient to enable the district court and this court to conclude that the ALJ considered plaintiff's medical condition as whole. The court held that the Appeals Council is not required to explain its rationale when denying a request for review and concluded that the new evidence plaintiff submitted did not render the Commissioner's denial of benefits erroneous. Accordingly, the court affirmed the judgment. View "Mitchell v. Commissioner, Social Security Administration" on Justia Law

The Hospital filed suit against various federal agencies and officials, seeking a declaratory judgment that 18 U.S.C. 4006(b)(1), where Congress has elected to impose the Medicare rate as full compensation for medical services rendered to federal detainees, is unconstitutional as applied. The court concluded that the Hospital voluntarily opted into the Medicare program and is, as a result, required to provide emergency services to federal detainees. Consequently, the Hospital was foreclosed from challenging this compensation scheme as an unconstitutional taking under the Fifth Amendment. The court noted that the Hospital's most effective remedy may lie with Congress rather than the courts. Accordingly, the court affirmed the district court's dismissal of the action.View "Baker County Medical Services v. U.S. Attorney General, et al." on Justia Law

The Board appealed the district court's grant of summary judgment in favor of plaintiffs, mother and son, requiring the Board to reimburse the mother for the cost of the placement of her son, who was diagnosed with autism, in a private school. A hearing officer later found that the Board failed to offer a free appropriate public education to the son before his third birthday, as required by the Individuals with Disabilities Education Act, 20 U.S.C. 1412(a)(1)(A), and that the Board instead consented to the son's placement at Mitchell's Place, a preschool that provided services and education to autistic children. The district court affirmed. The court concluded that the district court did not abuse its discretion when it weighed the equities and concluded that the County must reimburse plaintiffs. Accordingly, the court affirmed the judgment of the district court.View "Blount Cty. Bd. of Educ., et al. v. Bowens, et al." on Justia Law

Plaintiff filed a motion asking the court to approve the contingency fee arrangement he agreed to with his lawyer, following a successful claim for social security benefits. The magistrate judge determined that a fee in the amount of $11,876.65 was reasonable under 42 U.S.C. 406(b)(1). Plaintiff appealed. The court concluded that the magistrate judge correctly started with the fee agreement, and after determining that the early retirement benefits were not past-due benefits "owed," went on to conclude an independent review of the resulting fee for reasonableness. Accordingly, the court affirmed the fee award because the court agreed with the magistrate judge's interpretation of the contract and found no error in his review of the fee.View "Keller v. Commissioner of Social Security" on Justia Law

The Board challenged the district court's decision to award O.L.'s parents reimbursement for one-on-one instruction outside the school setting as well as some of their attorney's fees. The parents cross-appealed the district court's decision not to award O.L. compensatory education. The court concluded that the parents were eligible for reimbursement; the district court was right to find that the alternative program was proper under the standard set forth in Bd. of Educ. of Hendrick Hudson Centr. Sch. Dist., Westchester Cnty. v. Rowley; even if the alternative program has its shortcomings, it was reasonably calculated to permit the child to obtain some educational benefit; the district court's reimbursement award was appropriate; the district court did not abuse its discretion when it took the quality of the chosen alternative into consideration; it was clear on the record that the district court properly weighed the evidence and did not abuse its considerable discretion when it denied the request for compensatory education; and there was no need to reverse the attorney's fee award since the court affirmed the district court's decision in all respects.View "R.L., et al. v. Miami-Dade Cty. Sch. Bd." on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., alleging that LINA violated the disability insurance policy's terms and ERISA requirements - in part because LINA ignored the SSA process and the information it generated. The district court granted summary judgment in favor of LINA. Because LINA did not have the evidence presented to the SSA when it denied her last appeal - and in fact could not have had that evidence when it initially denied her claim - the court vacated the district court's judgment and remanded the case with instructions to remand plaintiff's claims to LINA for its consideration of the evidence presented to the SSA. View "Melech v. Life Ins. Co. of North America, et al." on Justia Law