Justia U.S. 7th Circuit Court of Appeals Opinion Summaries

Harold Grimes, a coal miner for 34 years, developed black lung disease and later died of lung cancer in 2018. His widow, Susan Grimes, is eligible for survivor’s benefits under the Black Lung Benefits Act. The dispute centers on whether Apogee Coal Company, Grimes’s last employer, or the Black Lung Disability Trust Fund should pay these benefits. The Department of Labor’s administrative law judge (ALJ) and the Benefits Review Board assigned financial responsibility to Apogee, with Arch Resources Inc., Apogee’s former parent corporation, bearing the liability. Arch contested this, arguing that the Trust Fund should pay.The district director initially identified Apogee as a potentially liable operator and notified Arch as Apogee’s “Insurance Carrier.” Despite Apogee’s bankruptcy in 2015, the district director and ALJ concluded that Arch, as Apogee’s self-insuring parent, was responsible for the benefits. The ALJ’s decision was based on the premise that Arch’s self-insurance umbrella covered Apogee’s liabilities. The Benefits Review Board affirmed this decision, referencing its prior cases, including Howard v. Apogee Coal Co., which supported the Department’s theory of liability for self-insuring parents.The United States Court of Appeals for the Seventh Circuit reviewed the case and found no statutory or regulatory basis for holding Arch liable for Apogee’s obligations. The court emphasized that neither the ALJ nor the Board identified a specific provision in the Act or its regulations that justified this liability. The court vacated the Board’s decision and remanded the case with instructions to assign Mrs. Grimes’s benefits to the Black Lung Disability Trust Fund. The court noted that future cases might provide additional arguments for such liability, but in this instance, the Trust Fund must pay. View "Apogee Coal Co. v. Office of Workers' Compensation Programs" on Justia Law

Scott Carlberg was convicted by a jury of four counts of wire fraud for fraudulently obtaining disability benefits from the United States Railroad Retirement Board (RRB). Carlberg, who had suffered a traumatic brain injury while working at Soo Line Railroad, applied for occupational disability benefits in 2013 and later for enhanced benefits in 2015. The RRB requires applicants to disclose any non-railroad work and earnings, which Carlberg failed to do accurately. Despite purchasing and operating a tanning salon, Carlberg misrepresented his work activities to the RRB, leading to his prosecution.The United States District Court for the Northern District of Illinois denied Carlberg’s motion to set aside the jury’s verdict, which argued that the evidence did not show he intentionally participated in a scheme to defraud or made material misrepresentations. The court found sufficient evidence that Carlberg had concealed his ownership and involvement in the salon, and that his misrepresentations were material to the RRB’s decision to grant him benefits. Carlberg was sentenced to 30 months’ imprisonment and ordered to pay $279,655.22 in restitution, representing the full value of the benefits he received.The United States Court of Appeals for the Seventh Circuit reviewed Carlberg’s appeal, which challenged both the denial of his motion for acquittal and the restitution award. The court found that the evidence at trial was sufficient to support the jury’s verdict, as it showed Carlberg engaged in significant physical and mental duties at the salon, which would have disqualified him from receiving benefits. The court also upheld the restitution award, agreeing that the government had proven the full amount of benefits Carlberg received was ill-gotten. The Seventh Circuit affirmed the district court’s decisions. View "United States v. Carlberg" on Justia Law

The case revolves around a dispute over attorney's fees in a Social Security disability benefits case. The plaintiff, Christian Arnold, was represented by the law firm Binder & Binder. After Arnold was determined to be disabled and entitled to past-due benefits, the law firm requested attorney's fees under 42 U.S.C. § 406(b), based on a contingency fee agreement Arnold had signed. However, the district court reduced the requested fees by nearly sixty percent, arguing that the full request would result in a "windfall" for the law firm, which was prohibited by statute. Binder & Binder appealed this decision.The case was initially heard by an administrative law judge (ALJ) who concluded that Arnold was not disabled. Arnold appealed this decision to the district court, which remanded the case back to the ALJ. On remand, the ALJ ruled in Arnold's favor, and the Social Security Administration issued a Notice of Award to Arnold for past-due benefits. Binder & Binder then moved for attorney's fees in the district court under 42 U.S.C. § 406(b), based on their contingency fee agreement with Arnold. The district court, however, reduced the requested fees.The United States Court of Appeals for the Seventh Circuit reviewed the case and concluded that the district court had abused its discretion by not basing its analysis primarily on the contingency agreement before considering the reasonableness of the request. The Court of Appeals vacated the district court's decision and remanded the case for further proceedings consistent with its opinion. The court emphasized that the contingency fee agreement should be the starting point for determining reasonableness under § 406(b), and any reduction should be justified based on relevant factors such as the claimant's satisfaction with their attorney's representation, the attorney's expertise and efforts expended, and the uncertainty of recovery and risks of an adverse outcome. View "Arnold v. O'Malley" on Justia Law

The case revolves around Brenda Warnell, who applied for disability insurance benefits and supplemental security income under the Social Security Act in 2019. Warnell claimed she was unable to work due to debilitating migraines and chronic pain in her back, shoulders, and neck. Her medical record was mixed, with some physicians assessing her as having severely limited functional capacity, while others found her capable of limited physical exertion.The Administrative Law Judge (ALJ) denied Warnell's claim, finding that the medical evidence did not substantiate the severity of her alleged functional limitations. The ALJ concluded that Warnell's pain symptoms did not prevent her from performing light work with moderate noise and limited physical requirements. The ALJ's decision was affirmed by the district court.In the United States Court of Appeals for the Seventh Circuit, Warnell challenged the ALJ's decision, arguing that the ALJ needed to provide more detailed accounts of the medical evidence. The court rejected this argument, stating that the ALJ's decision was supported by substantial evidence and met the light standard set by the Supreme Court. The court found that the ALJ had provided a sufficient explanation for her decision, highlighting specific evidence that contradicted Warnell's claims and addressing conflicting evidence. The court affirmed the ALJ's decision, rejecting Warnell's claim that the ALJ needed to provide more detailed accounts of the medical evidence. View "Warnell v. O'Malley" on Justia Law

In this appeal before the United States Court of Appeals for the Seventh Circuit, the plaintiff, Kelly Chavez, had been denied supplemental security income due to her various mental and physical impairments. The administrative law judge (ALJ) at a hearing found that Chavez could perform jobs that existed in significant numbers in the economy. This decision was affirmed by the district court, leading to this appeal. Chavez contended that the vocational expert's testimony, which the ALJ relied on, did not provide substantial evidence supporting the ALJ's decision.The vocational expert, Sarah Holmes, testified that a person with Chavez's age, background, and ability could perform several light exertion jobs, such as cleaner, office helper, and storage rental clerk. She used a software program, Job Browser Pro, to estimate the number of jobs, which uses data from the Bureau of Labor Statistics.Chavez's main argument was that Holmes did not explain Job Browser Pro's underlying formula, thereby rendering her testimony unreliable. However, the court held that Holmes's testimony provided substantial evidence for the ALJ's finding. The court highlighted that Holmes used a generally accepted source of job numbers, provided a straightforward overview of how the source worked, offered to provide additional information about the source's underlying formula, and identified jobs commonly found in the national economy. Therefore, the court affirmed the district court's judgment. View "Chavez v. O'Malley" on Justia Law

The plaintiff, Todd Hess, applied for supplemental security income, disability insurance benefits, and disabled adult child benefits, all of which are administered by the Social Security Administration. While his claims for supplemental security income and disability insurance benefits were approved, his claim for disabled adult child benefits was denied. To qualify for disabled adult child benefits, Hess had to prove that he had a disability that continued uninterrupted from before his 22nd birthday until the filing of his application for benefits. He claimed that his depression, panic disorder, obsessive-compulsive disorder, and other impairments made him disabled during that entire period. However, after two hearings, an Administrative Law Judge disagreed, concluding that Hess was disabled as of June 9, 2009, but not before then. The ALJ's decision was based on gaps in Hess's treatment history, notes from his physicians, and occasional work he performed as an independent contractor. The Appeals Council did not assume jurisdiction, and the district court found that the ALJ's decision was supported by substantial evidence. The United States Court of Appeals for the Seventh Circuit agreed and affirmed the judgment of the district court. View "Hess v. O'Malley" on Justia Law

Erik Bertaud, who suffered serious injuries when a tree branch fell on his head, applied for disability insurance benefits and supplemental security income from the Social Security Administration. His application was denied, and he appealed. The Appeals Council remanded the case twice, but after the third denial, Bertaud's request for review was denied, making the ALJ's decision the final decision of the Commissioner. Bertaud then sought judicial review, arguing that the ALJ had failed to develop the record of his disability, pointing to over 800 pages of new medical evidence. The district court denied Bertaud's motion for summary judgment and affirmed the Commissioner's decision, and Bertaud appealed to the United States Court of Appeals for the Seventh Circuit.The court held that although an ALJ has a duty to develop a full and fair record, this duty is limited when the claimant is represented by an attorney. The claimant's duty to submit evidence is ongoing and covers any additional related evidence they become aware of. The court noted that Bertaud was represented and his attorney had confirmed that the evidence was complete and supplemented the record when necessary. Therefore, the court concluded that the ALJ did not fail to develop Bertaud's medical record. The court affirmed the district court's decision denying Bertaud's motion for summary judgment and affirming the decision of the Commissioner. View "Bertaud v. O'Malley" on Justia Law

The case involves the plaintiff-appellant, Chris Martin, who suffered a back injury in June 2016 and stopped working. He sought medical attention in February 2018 and was diagnosed with a spine disorder in May 2018. Martin applied for Social Security disability benefits and was awarded supplemental security income after an administrative law judge (ALJ) found him disabled under the Social Security Act's stringent definition. However, he was denied disability insurance benefits because his insured status for those benefits had expired on December 31, 2017, a few weeks before he was found to have been disabled. Martin appealed, arguing that the ALJ should have consulted an additional medical expert to determine whether he was disabled earlier, before his insured status lapsed. The United States Court of Appeals for the Seventh Circuit concluded that the ALJ did not abuse her discretion in deciding not to consult another medical expert. The court explained that Social Security Ruling 18–01p allows an ALJ to decide whether to consult an additional medical expert to answer that question. Therefore, the court affirmed the denial of disability insurance benefits. View "Martin v. Kijakazi" on Justia Law

This is a dispute regarding a claim for Disability Insurance Benefits and Supplemental Security Income under the Social Security Act, brought by the plaintiff-appellant, Heather Tutwiler. The United States Court of Appeals for the Seventh Circuit affirmed the lower court's ruling that Ms. Tutwiler was not disabled within the meaning of the Social Security Act. The court found that the plaintiff had not engaged in substantial gainful employment since the onset date of her condition, and that her impairments significantly limited her ability to perform basic work activities. However, these impairments did not meet or equal the severity of any impairments listed in the Social Security regulations that lead to automatic findings of disability. The court noted that Ms. Tutwiler had the residual functional capacity to perform sedentary work with some additional restrictions. The court also found that jobs within Ms. Tutwiler’s abilities existed in the economy in such numbers that she was not disabled under the Social Security Act. The court held that the ALJ's decision was supported by substantial evidence and was not otherwise contrary to law. View "Tutwiler v. Kijakazi" on Justia Law

Fitschen was diagnosed with advanced cancer and stopped working. In 2000 the Social Security Administration (SSA) found Fitschen eligible for disability benefits. Fitschen returned to work in 2001 but continued to receive benefits for a nine-month “trial work period,” 42 U.S.C. 422(c)(4). After that period, he could continue to work and receive benefits for another 36-month period if his wages did not exceed the level at which a person is deemed to be capable of engaging in substantial work activity. The SSA's 2003 review determined that Fitschen had engaged in substantial work and should not have received benefits for much of 2002-2003. The SSA notified him of his overpayment liability but his benefits continued because he had again ceased substantial work. Fitschen again returned to work in 2004 but did not report the change. The SSA initiated another review in 2007 and suspended his benefits. The SSA may waive recovery of overpayments if the recipient was without fault.In 2019 the Commissioner of Social Security found Fitschen liable for an overpayment of $50,289.70 and declined to waive recovery. The district court and Seventh Circuit affirmed, rejecting an argument that the SSA was procedurally barred from recovering the overpayment because it failed to comply with its “reopening” regulation; the overpayment assessment did not “reopen” Fitschen’s initial eligibility determination or any later determination concerning the continuation or recomputation of his benefits. Substantial evidence supports the finding that Fitschen was at fault. View "Fitschen v. Kijakazi" on Justia Law