Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

Relator filed a qui tam action against Planned Parenthood, alleging that it violated the False Claims Act (FCA), 31 U.S.C. 3729-3733, and the Iowa False Claims Act (IFCA), Iowa Code Ann. 685.1-.7, by submitting false or fraudulent claims for Medicaid reimbursement. The district court dismissed the complaint under Rule 9(b). The court concluded that relator has pled sufficiently particularized facts to support her allegations that Planned Parenthood violated the FCA by filing claims for (1) unnecessary quantities of birth control pills, (2) birth control pills dispensed without examinations or without or prior to a physician's order, (3) abortion-related services, and (4) the full amount of services that had already been paid, in whole or in part. The court affirmed the dismissal of relator's claim that Planned Parenthood violated the FCA by instructing patients who experienced abortion-related complications to give false information to medical professionals at other hospitals, causing those medical professionals to unknowingly file claims for services performed in connection with abortions. Because relator failed to provide a factual basis for her knowledge of these alleged false claims, the court was unable to infer that false claims were submitted. Further, the court affirmed the dismissal of relator's upcoding claim. The court's holding with respect to the Rule 9(b) issue, however, should not be read as in any way expressing a view on Planned Parenthood's Rule 12(b)(6) arguments.View "Thayer v. Planned Parenthood" on Justia Law

Plaintiffs filed suit on behalf of themselves and a class, alleging a miscalculation of their Medicare Part B premium calculations. Plaintiffs conceded that they failed to exhaust administrative remedies. Because this case is not one of the exceptional cases where waiver of exhaustion is appropriate, the court affirmed the district court's determination that it lacked subject matter jurisdiction. The court affirmed the judgment of the district court on this issue and affirmed the district court's denial of mandamus relief where plaintiffs may pursue another avenue of relief, the administrative process.View "Degnan, et al. v. Sebelius, et al." on Justia Law

Plaintiff appealed the denial of disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. 401-434. The court agreed with the district court that the ALJ properly articulated his reasons for granting little weight to plaintiff's physician's opinions, and for finding the physician's opinions to be inconsistent with the record as a whole; that the ALJ properly considered plaintiff's medical records, observations of treating physicians, and plaintiff's own description of his limitations in making the residual functional capacity (RFC) assessment for plaintiff; and that the ALJ made a proper RFC determination based on a fully and fairly developed record. The court also concluded that substantial evidence exists in the record to support the ALJ's adverse credibility finding, and the district court did not abuse its discretion by failing to remand for reconsideration under 42 U.S.C. 405(g). Accordingly, the court affirmed the judgment of the district court. View "Whitman v. Colvin" on Justia Law

Plaintiff appealed the denial of her applications for disability insurance benefits (DIB) and supplemental security income (SSI). Plaintiff argued that the ALJ failed to give adequate weight to her treating physician's opinions regarding her disability. The court concluded that the ALJ had reason to discredit the physician's evaluation given the conclusory nature of his opinion and the court affirmed the judgment. View "Toland v. Colvin" on Justia Law

Plaintiff appealed the denial of his application for disability insurance benefits and supplemental security income (SSI) benefits. The court concluded that the ALJ did not err in concluding that plaintiff did not have a severe impairment that met the criteria of listing 12.04 (Affective Disorders); substantial evidence supported the ALJ's conclusion that plaintiff did not meet all the criteria for the listed impairment; the ALJ's determination of plaintiff's residual functional capacity (RFC) was supported by substantial evidence, and the ALJ did not err in declining to give a nurse practitioner's assessment controlling weight; and the hypothetical posed by the ALJ to the vocational expert was not defective. Accordingly, the court affirmed the denial of benefits. View "Blackburn v. Colvin" on Justia Law

Plaintiff appealed the denial of his application for disability insurance benefits (SSI) based on his post traumatic stress disorder, arthritis, headaches, hearing problems, back and knee problems, and acid reflux. The court concluded that the ALJ did not err in denying plaintiff benefits because the ALJ's decision was supported by substantial evidence on the record. View "Smith v. Colvin" on Justia Law

Plaintiff appealed the district court's denial of her application for supplemental security income benefits (SSI) based on her mental impairment. The court concluded that the record was not fully developed as to plaintiff's mental impairments. Accordingly, the court reversed and remanded for further development of the record. The ALJ shall reschedule plaintiff for an IQ test and other testing he deems appropriate before ruling on plaintiff's claim for benefits. View "Channell v. Colvin" on Justia Law

Plaintiff appealed the district court's order affirming the ALJ's determination that he was not entitled to disability benefits or supplemental security income. The court concluded that the ALJ's determination that plaintiff retained the residual functioning capacity to return to work as a truck driver was supported by substantial evidence. Because the ALJ did not proceed to step five of the five-step sequential process for evaluating disability claims on remand, vocational expert testimony was not required. Accordingly, the court affirmed the judgment of the district court. View "Hill v. Colvin" on Justia Law

An ALJ denied plaintiff's application for disability insurance benefits, concluding that she was not disabled because there were jobs she could have performed during the relevant period. The Appeals Council then denied review and plaintiff appealed the Commissioner's final decision to the district court. In this appeal, the government challenged the district court's reversal of the Commissioner's decision. The court reversed and affirmed the Commissioner's final decision, concluding that the ALJ's decision was supported by substantial evidence on the record. View "Turpin v. Colvin" on Justia Law

Plaintiff appealed the district court's decision upholding the Commissioner's determination that he was not entitled to waiver of recovery of overpaid disability benefits. The court concluded that substantial evidence supported the Commissioner's decision where recovery of the overpayment did not defeat the purpose of Title II of the Social Security Act, 42 U.S.C. 301 et seq., and where recovery of the overpayment was not against equity or good conscience because plaintiff's mere receipt of disability benefits after notifying the Commissioner of his work activity did not satisfy 20 C.F.R. 404.510a. Accordingly, the court affirmed the judgment of the district court. View "Rodysill v. Colvin" on Justia Law