Case Summaries

Government Benefits

[02/03] Sauer v. Dep't of Education
In a suit by a California state agency seeking review of an arbitration award that made it liable to a blind vendor for failing to sue the federal General Services Administration (GSA) to vindicate the rights of the vendor to conduct business on federal property, the district court's judgment affirming the award is reversed, where: 1) the arbitration panel committed a legal error when it interpreted the Randolph-Sheppard Vending Stand Act as requiring the state agency to bring an action against GSA, and that the agency's failure to do so made it liable for compensatory damages; and 2) because the arbitration panel's ruling was not in accordance with law, it had to be set aside under the Administrative Procedure Act.

[01/31] Fowlkes v. Thomas
On a prisoner's postjudgment motion for an order directing the Social Security Administration (SSA) to re-tender a check for retroactive supplemental Social Security benefits that he was owed, the district court’s denial of the motion is affirmed, as: 1) the No Social Security Benefits for Prisoners Act bars the SSA from making any payment to an incarcerated individual covered by the Act, regardless of when the underlying obligation to pay the individual arose; and 2) the Act is not impermissibly retroactive, because it alters only the procedure and timing by which certain individuals receive their retroactive Social Security benefit payments, and does not affect their substantive right to those benefits.

[01/27] Hutcherson v. Arizona Health Care Cost Containment System Administration
In a declaratory judgment action seeking a declaration that Arizona's Medicaid agency had no right at all to recover from an annuity purchased by a husband so that his institutionalized wife could obtain Medicaid coverage or, alternatively, had no right to recover for any costs incurred for the wife's care after the husband's death, the district court's grant of the defendant's motion for summary judgment is affirmed, where: 1) the federal Medicaid Act allows states to reach a deceased community spouse's annuity for costs incurred on behalf of an institutionalized spouse; and 2) nothing in the language of the Act was inconsistent with permitting the state agency to recover from the annuity expenses incurred after the husband's death.

[01/20] National Organization of Veterans' Advocates, Inc. v. Secretary of Veterans Affairs
In a challenge to a rule issued by the Secretary of Veterans Affairs with respect to claims for service-connected disability benefits for posttraumatic stress disorder, a petition to review the final rule is denied where, under a Chevron analysis: 1) no existing statute or regulation specifically addresses the issue raised in the rule so as to create a conflict or contradiction; 2) the court could not say that the rationale behind the rule is without a logical basis, or is otherwise arbitrary and capricious.

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Workers' Comp

[01/11] Pacific Operators Offshore, LLP v. Valladolid
In an appeal from a judgment of the appeals court vacating an administrative dismissal of respondent's Outer Continental Shelf Lands Act (OCSLA) claim for benefits as a surviving spouse, judgment is affirmed where a claimant seeking benefits under the OCSLA must establish a substantial nexus between the injury and extractive operations on the shelf.

[12/13] In the Matter of Elrac, Inc. v. Exum
In an appeal from a judgment of the appellate division permitting arbitration of a claim by plaintiff-employee for uninsured motorist benefits, judgment is affirmed because a self-insured employer whose employee is involved in an automobile accident may be liable to that employee for uninsured motorist benefits, notwithstanding the exclusivity provision of the Workers' Compensation Law.

[10/31] County of Kern v. Workers' Comp. Appeals Bd
In an appeal from a judgment of the trial court affirming an administrative decision in a claim for worker's compensation, judgment is affirmed where a volunteer firefighter with a local nonprofit firefighting organization was a county employee for purposes of workers' compensation coverage under Labor Code section 3361.1.

[09/13] Motheral v. Workers' Compensation Appeals Board
In a petition for review of a judgment of the defendant-Board denying reconsideration of an administrative decision calculating petitioner's disability benefits based solely on his full-time employment at minimum wage, Lab. Code section 4653, judgment is reversed where section 4454 mandates the inclusion of the market value of petitioner's living quarters, utilities, and car allowance.

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