Justia U.S. 5th Circuit Court of Appeals Opinion Summaries

Plaintiffs filed suit against the City, arguing that the City's pension reforms violate the Texas Constitution, Tex. Const. art. XVI 66(d). Two district courts ruled in favor of the City. In these consolidated appeals, the court concluded that Section 66 permits prospective changes to the pension plans of the public employees within its reach. In this case, the Pension Reform complies with Section 66 where Section 66 did not turn plaintiffs’ variable-rate cost-of-living adjustment into a one-way ratchet capable only of upward movement. The court rejected claims raised by plaintiffs of Case No. 15-10416, that only the Texas legislature has the City of Dallas v. Trammel "reserved power" to amend pension plans and thus abrogate contractual rights. The court concluded that this argument is foreclosed by Klumb v. Houston Mun. Employees Pension Sys. Finally, the court concluded that the Pension Reform does not violate the United States Constitution’s contracts clause and takings clause where neither clause create property rights and the right to public pension benefits in Texas is subject to legislative power. Accordingly, the court affirmed the district court's judgments. View "Houten, Jr. v. City of Fort Worth" on Justia Law

Plaintiff, complaining chiefly of neck pain, appealed the denial of his application for disability benefits. The court concluded that the newly submitted evidence - namely, updated treatment records - was not so significant as to require remand to the ALJ for additional consideration; substantial evidence supports the ALJ's determination at step three of the evaluation process that plaintiff did not meet or medically equal Listing 1.04(A); and the ALJ's residual functioning capacity (RFC) finding is supported by substantial evidence where the ALJ found that plaintiff was capable of performing light work with certain limitations. The court agreed with the ALJ's ultimate determination that plaintiff was not disabled and affirmed the judgment. View "Whitehead v. Colvin" on Justia Law

Plaintiffs, a class of children eligible for Texas's Early and Periodic Screening, Diagnosis, and Treatment program, filed suit under 42 U.S.C. 1983 for violations of federal Medicaid law. Plaintiffs subsequently entered into a consent decree with various Texas state officials (defendants) calculated to improve implementation of the Program. In 2007, the parties agreed to a "Corrective Action Order." In 2013, defendants moved to terminate a portion of the Order and associated consent decree paragraphs under Rule 60(b)(5). The district court granted the motion and plaintiffs appealed. Determining that plaintiffs have not forfeited their appeal, the court concluded that the district court properly terminated the portion of bullet points 8-10 concerning the completion of the four assessments at issue. The court relied on certain district court decisions to interpret the proper interpretation of "shortage" - which compares the provider-to-class-member ratio with the average client load of the relevant class of provider - and concluded that the district court erred in terminating the portion of bullet points 8-10 that orders defendants to develop plans to address “shortage[s]” identified by the assessments. Accordingly, the court vacated the district court's order in part and remanded for further proceedings. The court affirmed the portion of the district court’s order terminating bullet points 6-7 and consent decree paragraph 93, and the court vacated the portion of the district court's order terminating the challenged sentence of bullet point 5. View "Frew v. Janek" on Justia Law

Parents of M.C. appealed the district court's denial of reimbursement for tuition in a private school under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. In this case, the parents adopted an all-or-nothing approach to the development of M.C.'s Individualized Educational Plan (IEP) and they adamantly refused to consider any of the school district's alternative proposals. The court affirmed the district court's denial of reimbursement because the district court’s findings and the underlying record support the conclusion that M.C.’s parents acted unreasonably in unilaterally terminating the process of developing M.C.’s IEP. View "Rockwall Indep. Sch. Dist. v. M. C." on Justia Law

Plaintiffs filed suit on behalf of their minor son seeking attorneys' fees under the Individuals with Disabilities Education Act's (IDEA), 20 U.S.C. 1415(i)(3)(B), fee-shifting provision. The district court held that plaintiffs were the prevailing party by virtue of having obtained a “stay-put” order under the IDEA and awarded plaintiffs attorneys’ fees. The court held that plaintiffs are not the prevailing party by virtue of having invoked the IDEA's stay-put provision and the court concluded that its holding is consistent with several other circuit courts that have addressed the issue. Contrary to the district court’s conclusion, the ALJ’s stay-put order was not a ruling on the merits; nor is the stay-put order a “similar form of judicially sanctioned relief” sufficient to confer prevailing party status; the court disagreed with the district court’s reasoning that the stay-put order was essentially a preliminary injunction and that pursuant to the court's case law in this context, plaintiffs were entitled to attorneys’ fees; and, in Davis v. Abbott, the court recently reiterated the importance of a party having achieved relief on the merits for the purposes of determining prevailing party status in the context of interlocutory injunctive relief. Accordingly, the court reversed and rendered judgment for defendants. View "Tina M. v. St. Tammany Parish Sch. Bd." on Justia Law

Parents of Seth B., a child diagnosed with autism, obtained an independent educational evaluation (IEE) and sought reimbursement. The district court subsequently ruled that the reimbursement was not warranted. The court concluded that the school board did not waive its right to refuse reimbursement and the proceedings before the district court were procedurally sound; the application of Bulletin 1508 did not violate the right to an IEE in this case; the court remanded for analysis under a substantial compliance standard where Seth’s IEE will “meet agency criteria” and merit reimbursement if it substantially complies with Bulletin 1508; but Parents will not be entitled to the full cost of the evaluation they obtained because they knew of the school board's cost cap of $3,000 and yet spent over $8,000. Accordingly, the court vacated and remanded. View "Seth B. v. Orleans Parish Sch. Bd." on Justia Law

Plantiff filed suit challenging the denial of his claim for disability benefits under Title II of the Social Security Act, 42 U.S.C. 423. Because the ALJ based his decision on a credibility assessment of plaintiff's testimony without holding an additional hearing as required by the Hearings, Appeals, and Litigation Law Manual (HALLEX), the court held that defendant was prejudiced by the HALLEX violation. Accordingly, the court reversed and remanded with instructions that the case be remanded to the Commissioner for further proceedings. View "Morgan, Jr. v. Colvin" on Justia Law

Plaintiff appealed the denial of her claims for disability insurance benefits (DIB) and supplemental security income benefits (SSI) based on a fractured ankle in 2011. The ALJ denied her claim, concluding that plaintiff's impairment did not equal the medical severity of an impairment listed in the C.F.R., which required plaintiff to show that her ankle injury rendered her unable to ambulate effectively for a full year after the May 2011 onset. Plaintiff requested review of her claim and submitted additional medical records. The Appeals Council made this additional evidence part of the record but denied the review without providing discussion of the newly submitted evidence. The court reversed and remanded for further proceedings because the court was unable to determine, from review of the record as a whole, if substantial evidence supports the Commissioner’s denial of benefits. View "Sun v. Colvin" on Justia Law

This action began in 1993 when Plaintiffs, representatives of a class of over 1.5 million Texas children eligible for Medicaid’s Early and Periodic Screening, Diagnosis, and Treatment program ("EPSDT"), sued various Texas state officials under 42 U.S.C. 1983 for violations of federal Medicaid law in the state’s implementation of the Program. The parties concluded a consent decree in 1996 in which Defendants promised to implement a number of changes, among which was a training program for participating health care providers. A few years later, after little progress had been made, the district court found Defendants in violation of the Decree. The Fifth Circuit reversed solely on Defendants' challenge to the Decree's validity under the Eleventh Amendment. In 2007, the parties agreed on a corrective action order to resolve Plaintiffs’ concerns with one part of the Decree. Defendants, believing their obligations to be satisfied, moved to dissolve that order and the associated Decree provisions under Rule 60(b)(5). The district court granted their motion. Plaintiffs appealed the district court’s termination of several provisions of the Decree decree and the dissolution of a related corrective action order pursuant to the first clause of Federal Rule of Civil Procedure 60(b)(5), that the judgment has been “satisfied, released, or discharged.” Finding no reversible error, the Fifth Circuit affirmed. View "Frew v. Suehs" on Justia Law

Plaintiff appealed the denial of her application for disability insurance benefits (DIB) and supplemental security income (SSI) benefits. The court vacated the district court's dismissal of plaintiff's complaint and remanded, holding that a rebuttable presumption against substantial gainful activity arises where a disability claimant's earnings are below the threshold set by the relevant statutory regulations. In this case, the Commissioner's failure to address plaintiff's earnings and apply the presumption is grounds for reversal. View "Copeland v. Colvin" on Justia Law