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

The Eighth Circuit affirmed the denial of social security benefits to plaintiffs, rejecting plaintiffs' claim that the ALJs who denied their claims were not properly appointed under the Appointments Clause of the Constitution. The court held that plaintiffs' unexhausted claims are foreclosed by Davis v. Saul, 963 F.3d 790 (8th Cir. 2020), cert. granted, 2020 WL 6551772 (Nov. 9, 2020) (No. 20-105). View "Smith v. Saul" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's challenge to the Commissioner's denial of her application for disability insurance benefits and supplemental security income. The court held that substantial evidence supported the ALJ's determination concerning the limits of plaintiff's ability to reach and handle throughout an otherwise sedentary workday. In this case, one of the jobs cited by the vocational expert as available in the national economy—call out operator—requires only occasional, rather than frequent, handling. Therefore, the identified job is even less demanding on plaintiff's upper extremities than would be permitted by the Commissioner's residual functional capacity limitation. View "Lawrence v. Saul" on Justia Law

Independent of the Individuals with Disabilities Education Act (IDEA), Minnesota has adopted an "open enrollment" process that allows a parent to enroll a student in a school outside of the student's local district.The Eighth Circuit held that the IDEA does not require a school district that enrolls a nonresident student like M.N.B. to provide transportation between the student's home and the school district where her parent has chosen to enroll her. The court saw nothing in the IDEA that provides clear notice to a state that it must cover transportation expenses when a student's travel is the result of a parent's choice under an open enrollment program. Therefore, under the circumstances presented here, the court concluded that the IDEA does not require the Osseo District to reimburse M.N.B.'s parent for the cost of transportation between her home and the border of the Osseo District. The court reversed the district court's grant of summary judgment in favor of M.N.B. View "Osseo Area Schools v. M.N.B." on Justia Law

The Eighth Circuit affirmed the denial for disability insurance benefits and supplemental security income to plaintiff. The court held that the ALJ properly weighed the opinions of medical professionals, including a physician's assistant, and gave partial weight to the opinion of a certain medical expert. The court also held that sufficient evidence in the record supported the ALJ's decision, including clinical notes that plaintiff lost weight from moving around so much, left a clinical appointment with a brisk walk and no cane, and stated he was doing well after a total hip replacement. Finally, the court held that a hypothetical question given to the vocational expert captured the concrete consequences of plaintiff's impairments, and the court need not consider plaintiff's Appointments Clause challenge. View "Hilliard v. Saul" on Justia Law

The Eighth Circuit reversed the district court's dismissal of a petition for review of the Commissioner's denial of plaintiff's application for disability insurance benefits and supplemental security income. The court held that, although the record provides ample support for determinations regarding the severity and limiting effect of most of plaintiff's impairments, further development is required as to the functional limitations on walking and standing. Therefore, the court remanded for further proceedings. View "Noerper v. Saul" on Justia Law

Plaintiffs each brought an action asserting that the ALJ who denied their application for benefits was not properly appointed in accordance with the Appointments Clause of the Constitution.The Eighth Circuit held that the district court properly declined to consider the issue and affirmed the judgments. In these cases, none of the claimants raised the issue during the proceedings before the Social Security Administration and thus the district court properly concluded that they waived their argument. The court rejected plaintiffs' claims that their constitutional claims need not be exhausted and that exhaustion of this particular constitutional challenge would have been futile. The court further explained that this is not one of the rare situations in which a federal court should consider an issue that was not presented to the agency. View "Davis v. Saul" on Justia Law

The Eighth Circuit reversed the district court's order affirming the ALJ's denial of plaintiff's application for disability benefits. The court held that the ALJ's error in failing to provide good reason for giving plaintiff's treating psychiatrist's opinion limited weight was not harmless error. In this case, the failure to comply with SSA regulations is more than a drafting issue, it is legal error. Furthermore, the court cannot determine whether the ALJ would have reached the same decision denying benefits, even if the ALJ had followed the proper procedure for considering and explaining the value of the psychiatrist's opinion. Accordingly, the court remanded for further administrative proceedings and for reconsideration of plaintiff's claims. View "Lucus v. Saul" on Justia Law

The Eighth Circuit affirmed the denial of social security disability benefits to plaintiff, holding that substantial evidence supported the ALJ's residual functional capacity (RFC). The court held that the ALJ's finding that plaintiff can perform frequent but not constant grasping, handling, and fingering with her right arm is supported by substantial evidence. View "Pemberton v. Saul" on Justia Law

Plaintiffs filed suit under the Individuals with Disabilities Education Act (IDEA), bringing a due process challenge to the school district's individualized education plan (IEP) and school placement before the Missouri Administrative Hearing Commission. The Commission affirmed the plan and placement, denying reimbursement. The district court reversed the Commission but limited the reimbursement award based on equitable considerations.The Eighth Circuit held that the school district violated the IDEA and the district court erred in limiting the award. As a preliminary matter, the court held that the school district's jurisdictional challenge was without merit; the school district's mootness challenge also failed; and the district court properly placed the burden on plaintiffs in the proceeding before it and correctly stated the standard of review on appeal.On the merits, the court held that the school district denied plaintiffs' son a free and appropriate education as required by the IDEA when it placed him at a school without direct occupational therapy or a sensory diet plan in place to address his autism-related issues. The court also held that an award limitation based on improvements to the school was inappropriate and inconsistent with the purposes of the IDEA because the school district failed to give any notice to plaintiffs. Furthermore, limiting an award based on improvements not communicated to plaintiffs was inconsistent with the IDEA's purpose. Accordingly, the court reversed the district court's limitation of tuition reimbursement and awarded full tuition reimbursement. View "D. L. v. St. Louis City School District" on Justia Law

The Eighth Circuit affirmed the district court's denial of supplemental security income to claimant, who suffers from borderline intellectual functioning, learning delays, schizoaffective disorder, mood disorder, personality disorder, and an anxiety disorder. The court held that substantial evidence supported the ALJ's determination that claimant was not disabled within the meaning of the social security guidelines and listings regardless of which Section 12 mental disorder listing was considered. View "Cronin v. Saul" on Justia Law