Justia U.S. 10th Circuit Court of Appeals Opinion Summaries

Plaintiff-Appellant Carl Sheppard appealed the district courtâs order which denied his applications for disability insurance and supplemental security income benefits under the Social Security Act. The Administrative Law Judge (ALJ) denied Plaintiffâs applications for benefits in January, 2008 because the part-time work Plaintiff was doing at the time of his application was âsubstantial gainful activity.â The Tenth Circuit found that the ALJ failed to apply the correct legal standards in arriving at his conclusion. Accordingly, the Court reversed the lower court and remanded the case for further proceedings.

Plaintiff-Appellant Jessica Cohon sought funding through New Mexicoâs Medicaid program. She qualified for the âMi Via Waiverâ program, and submitted budget requests which were partly granted, partly denied. After an unsuccessful administrative appeal, she filed suit, alleging that the administration of the Mi Via Waiver program discriminated against severely disabled persons like herself. The State moved to dismiss Plaintiffâs complaint, arguing that not only was it the wrong entity being sued, but that Plaintiff had no statutory basis to support her suit. The district court dismissed Plaintiffâs claims based on federal law, but remanded her state-law claims to the administrative agency for further proceedings. Plaintiff appealed the dismissal of her federal law claims to the Tenth Circuit. Upon review, the Tenth Circuit found Plaintiffâs federal claims âinsufficient in substance,â and affirmed the judgment of the district court that dismissed her claims.

Plaintiff Richard Krauser appealed the district courtâs order that denied him social security and supplemental security income benefits. The Administrative Law Judge (ALJ) denied Plaintiffâs benefits on the last step of a five-step process for determining his eligibility. Among other things, the ALJ found that Plaintiffâs ailments had not met the âper seâ disabling impairments that would have made him eligible, and considering his age, education and transferable work skills, Plaintiff could go back to work. The appeals council denied review, making the ALJâs decision ripe for the Tenth Circuit to review. Plaintiff argued that the ALJ did not properly consider all of his impairments and came to the wrong conclusion after the five-step process. The Tenth Circuit found that the ALJ did not review all evidence Plaintiff submitted, particularly statements from Plaintiffâs treating physician. The Court reversed the ALJâs holding and remanded the case for further review.

Plaintiff appealed the administrative law judge's ("ALJ") denial of his application for supplemental security income alleging that he became disabled beginning in March 20, 2005 due to depression, post-traumatic stress disorder, and schizoaffective disorder. At issue was whether the factual findings were supported by substantial evidence and whether the correct legal standards were applied. The court held that the ALJ did not follow the law in evaluating all the medical evidence from a licensed clinical psychologist, a licensed professional counselor, and a physician who diagnosed plaintiff with schizoaffective disorder. The court also held that the ALJ failed to apply the correct legal standards in assessing plaintiff's credibility, and alternatively, the ALJ's adverse credibility determination was not supported by substantial evidence.