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

Plaintiff appealed the district court's decision affirming the Commissioner's denial of social security benefits. The court rejected plaintiff's contention to the extent that she alleged the ALJ failed to develop the record or make explicit findings regarding the mental and physical demands of her past relevant work as a factory packer and assembler. The court concluded that the ALJ had sufficient evidence on the record as a whole to reach his determination where the ALJ adequately compared the demands of plaintiff's past with her residual functioning capacity to perform light work, including with her manipulative limitations. Accordingly, the court affirmed the denial of benefits. View "Young v. Astrue" on Justia Law

Plaintiff appealed from the magistrate judge's decision affirming the Commissioner's denial of social security disability insurance benefits. The court held that, when viewing the entire record, it perceived no error in the minimal weight the ALJ afforded plaintiff's treating neurologist's evaluation and concluded that substantial evidence supported the ALJ's decision. Accordingly, the court affirmed the judgment. View "Anderson v. Astrue" on Justia Law

Perks applied for disability insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. An ALJ denied Perks's application. On appeal to the appeals council, Perks submitted additional evidence. The appeals council noted the receipt of the additional evidence but denied further review of Perks's claim. The district court affirmed. The Eighth Circuit Court of Appeals affirmed, holding (1) substantial evidence supported the ALJ's finding that Perks was not disabled; and (2) the additional evidence submitted to the appeals council did not undermine the ALJ's determination, as the ALJ would not have reached a different result with the additional evidence and the ALJ's decision was supported by substantial evidence in the record as a whole. View "Perks v. Astrue" on Justia Law

Kevin Byes applied for disability insurance benefits and supplemental security income on July 30, 2007, claiming disability since November 1, 2005. The Commissioner of Social Security Administration (Commissioner) denied benefits. An administrative law judge (ALJ) upheld the Commissioner's decision, concluding that Byes was not disabled from November 1, 2005 through the date of the decision. The district court agreed with the ALJ's decision. The Eighth Circuit Court of Appeals affirmed, holding that substantial evidence supported the ALJ's finding of no severe mental impairment; and (2) the district court correctly concluded that the ALJ had applied the incorrect grid rule in order to determine Byes was not disabled but that the error was harmless. View "Byes v. Astrue" on Justia Law

Defendant Barbara Norris, an organizational payee with the Social Security Administration, pled guilty to social security representative payee fraud. The district court sentenced Defendant to eighteen months in prison, the top of her guideline range. Defendant appealed, arguing that her sentence was substantively unreasonable. The Eighth Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in sentencing Defendant to eighteen months in prison, as the court properly applied its wide latitude to weigh the factors in the federal sentencing statute and assigned some factors greater weight than others in determining an appropriate sentence. View "United States v. Norri" on Justia Law

The Secretary of the Department of Health and Human Services (HHS) imposed a civil money penalty on Greenbrier Nursing and Rehabilitation Center, a skilled nursing facility in Arkansas, for noncompliance with Medicare participation requirements. The Eighth Circuit Court of Appeals denied Greenbrier's petition for review, holding (1) substantial evidence supported HHS's finding that Greenbrier was not in substantial compliance with 42 C.F.R. 483.25; (2) the finding that Greenbrier's noncompliance with section 483.25 rose to the level of immediate jeopardy was not erroneous; and (3) judicial review of two of Greenbrier's objections to the monetary penalty was barred, and Greenbrier received adequate notice of its noncompliance. View "Greenbrier Nursing v. U.S. Dep't of Health & Human Servs." on Justia Law

Appellant sought disability insurance benefits for his ongoing back pain, lower extremity problems, neck pain, sleep apnea, and anxiety. An ALJ upheld the Commissioner's denial of benefits after concluding that appellant maintained the residual function capacity (RFC) to perform light work and the district court affirmed. The court concluded that the Commissioner's decision was supported by substantial evidence and affirmed.

T.B.'s parents, on behalf of their autistic child, appealed the district court's finding that the school district did not violate the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., by failing to provide a free appropriate public education (FAPE) to T.B., making the parents ineligible for reimbursement for the costs of T.B.'s home-based program. Given the parents' decision to ultimately settle the issue of the adequacy of the proposed individualized education program (IEP), the court questioned whether they could claim, much less successfully show, that the school district failed to provide a FAPE to T.B. Nonetheless, based on the record, the court could not say that T.B.'s home-based program was "reasonably calculated to enable [him] to receive educational benefits." The program was therefore not "proper" within the meaning of the IDEA and the parents were not entitled to reimbursement for the costs associated with it. Accordingly, the court affirmed the judgment.

This case addressed the effect of a pooled special-needs trust created by an over-65-year-old beneficiary on his medicaid benefits. The Center for Special Needs Trust Administration appealed a summary judgment in favor of the North Dakota Department of Human Services. Invoking 42 U.S.C. 1983 and the Constitution's Supremacy Clause, the Center alleged that North Dakota's demand for reimbursement and its state regulations violated a paragraph of the Medicaid Act, 42 U.S.C. 1396p(d)(4)(C). The court held that the district court properly determined that section 1396p(d)(4)(C) afforded the Center a right of action under section 1983; that North Dakota did not waive its claim to recover for reimbursements and should not be estopped from making that claim; that the Center's claim was without merit; and that preemption did not apply.

Plaintiff appealed the district court's order affirming the Commissioner's denial of his application for supplemental security income benefits. Specifically, he objected to the ALJ's finding, without considering the testimony of a vocational expert, that plaintiff was able to engage in gainful activity. The court concluded that the ALJ erred by relying solely on the guidelines to determine plaintiff was "not disabled." Because the ALJ determined that plaintiff suffered from severe mental impairments, the ALJ should have consulted a vocational expert in determining whether plaintiff had the residual functional capacity to perform other jobs that existed in significant number in the national economy. Accordingly, the court reversed and remanded for further proceedings.