Laird v. Stilwill

Decision Date25 October 1997
Docket NumberNo. C 95-3015-MWB.,C 95-3015-MWB.
Citation982 F.Supp. 1345
PartiesPaula LAIRD, on her own behalf and on behalf of all others similarly situated, and William Meeks, on his own behalf and on behalf of all others similarly situated, Plaintiffs, v. Ted STILWILL, in his official capacity as Director of the Iowa Department of Education, Defendant, and John J. Callahan, Acting Commissioner of the Social Security Administration, Intervenor/Defendant.
CourtU.S. District Court — Northern District of Iowa

Thomas A. Krause, Max Schott & Associates, Des Moines, IA, for plaintiffs Paula Laird and William Meeks and the conditionally certified class.

Christie J. Scase, Assistant Attorney General, Des Moines, IA, for defendant Ted Stilwill.

Richard G. Lepley, Daphene R. McFerren, Department of Justice, Civil Division, Washington, DC, for defendant John A. Callahan.

MEMORANDUM OPINION AND ORDER REGARDING DEFENDANTS' MOTIONS TO RECONSIDER JURISDICTION AND TO RECONSIDER ORDER GRANTING PARTIAL SUMMARY JUDGMENT

BENNETT, District Judge.

                TABLE OF CONTENTS
                I. INTRODUCTION ................................................ 1346
                 II. LEGAL ANALYSIS .............................................. 1347
                     A. Reconsideration Of Subject Matter Jurisdiction ........... 1347
                        1.  Applicable standards ................................. 1347
                        2.  This court's prior decision .......................... 1348
                        3.  The Blessing decision ................................ 1350
                        4.  Analysis in the wake of Blessing ..................... 1351
                     B. Reconsideration Of Partial Summary Judgment .............. 1353
                        1.  Procedural basis and standard of review .............. 1353
                        2.  This court's prior decision .......................... 1355
                        3.  The defendant's challenge ............................ 1355
                            a.  Deference ........................................ 1356
                            b.  The key threshold question ....................... 1357
                            c.  Agency ruling and the need for acquiescence. ..... 1357
                            d.  IDDSB determination .............................. 1358
                III. CONCLUSION .................................................. 1358
                

How much federal oversight of a state agency administering a federal program precludes a private action pursuant to 42 U.S.C. § 1983 to compel the state agency to comply with federal law? That is the principal question presented in motions renewing challenges to this court's subject matter jurisdiction over this action. In a prior decision, this court held, in part, that federal oversight of a state agency that makes initial disability determinations under Titles II and XVI of the Social Security Act (SSA) was insufficient to preclude a private cause of action pursuant to 42 U.S.C. § 1983 against the director of the state agency to enforce proper standards and procedures.1 The director of the state agency and the intervenor Acting Commissioner of the Social Security Administration, however, assert that the Supreme Court's recent intervening decision in Blessing v. Freestone, ___ U.S. ___, 117 S.Ct. 1353, 137 L.Ed.2d 569 (1997), requires reconsideration and reversal of that holding. Thus, the court must consider renewed challenges to its subject matter jurisdiction over the plaintiffs' § 1983 claims. Additionally, the defendant and intervenor assert that, in another decision, this court improvidently granted partial summary judgment in favor of the plaintiffs on their claim that the state defendant fails to evaluate properly subjective complaints of pain in making disability determinations under the SSA. Thus, the court is called upon to reconsider not only its jurisdiction to hear the case, but one of its conclusions made in the exercise of that jurisdiction.

I. INTRODUCTION

This court has twice reviewed in some detail the background and claims asserted in this litigation, once in ruling on a motion to dismiss for lack of subject matter jurisdiction, see Laird v. Ramirez, 884 F.Supp. 1265 (N.D.Iowa 1995) (hereinafter "Laird I"), and once in ruling on cross-motions for summary judgment and partial summary judgment. See Laird v. Stilwill, 969 F.Supp. 1167 (N.D.Iowa 1997) (hereinafter "Laird II").2 Thus, only a brief review of the background to this litigation is required here.

This is a class-action lawsuit brought pursuant to 42 U.S.C. § 1983 for declaratory and injunctive relief, not benefits, by persons initially determined by the Iowa Disability Determination Service Bureau (IDDSB) not to be disabled within the meaning of Titles II or XVI of the SSA. Count I of the class-action complaint seeks relief from disability evaluations by the state defendant that are in violation of the SSA, pertinent regulations, and controlling federal judicial decisions, in four specified respects: evaluation of subjective pain allegations; credibility determinations; use of qualified vocational specialists; and documentation and completeness of assessments of residual functional capacity. Count II seeks relief from disparate treatment of applicants for disability benefits at the state and federal administrative levels, which plaintiffs allege has created two classes of applicants based on their resources and stamina to pursue federal administrative procedures, in violation of the equal protection clause of the Fourteenth Amendment to the United States Constitution.

In Laird I, 884 F.Supp. at 1265, the court found it had subject matter jurisdiction over both § 1983 claims, despite provisions for appeal and review of individual disability determinations and federal oversight of the state agency. In Laird II, 969 F.Supp. at 1167, the court granted partial summary judgment in favor of the plaintiffs on that part of Count I in which they claim that the state defendant fails to evaluate subjective complaints of pain in accordance with Eighth Circuit precedent. The state and federal defendants have moved the court to reconsider both of these rulings.

II. LEGAL ANALYSIS

Although the defendants' renewed challenges to jurisdiction over any § 1983 claims and the grant of partial summary judgment are couched as motions to "reconsider," the court finds that different standards are applicable to the motions based on precisely what it is the court is asked to reconsider. Therefore, the court will consider the standards for and merits of these motions separately, beginning with the renewed challenge to the court's power to hear the case at all. If the court finds that it has subject matter jurisdiction over the plaintiffs' § 1983 claims, the defendants' assertions notwithstanding, the court will then take up the standards for and merits of the motion to "reconsider" the grant of partial summary judgment in favor of the plaintiffs.

A. Reconsideration Of Subject Matter Jurisdiction

The defendants have asked the court to reconsider its conclusion that the SSA does not preclude a private action pursuant to 42 U.S.C. § 1983 to compel a state agency to apply proper standards — embodied in the SSA itself, regulations promulgated under the SSA, and case law of this circuit — to initial determinations of disability under Titles II and XVI of the SSA. Indeed, at the hearing on the cross-motions for summary judgment and partial summary judgment, the court sua sponte invited the parties to address the effect, if any, on this case of the Supreme Court's recent decision in Blessing v. Freestone, ___ U.S. ___, 117 S.Ct. 1353, 137 L.Ed.2d 569 (1997), which considered the viability of § 1983 claims to enforce provisions of Title IV-D of the SSA. Although the defendants' motions to "reconsider" subject matter jurisdiction followed in due course, the defendants do not discuss the standards applicable to such motions and do not identify any rule of civil procedure as the basis for their motions. Thus, the first question is, by what standards are these motions to "reconsider" to be decided?

1. Applicable standards

As this court observed in Laird I, the federal courts "`are not courts of general jurisdiction and have only the power that is authorized by Article III of the Constitution and the statutes enacted by Congress pursuant thereto.'" Laird I, 884 F.Supp. at 1270 (quoting Marine Equip. Management Co. v. United States, 4 F.3d 643, 646 (8th Cir. 1993)). Because of their limited jurisdiction, federal courts have a duty to examine the substantiality of the federal claim throughout the litigation, and must dismiss all claims if the federal claim proves patently meritless even after the trial begins. Id. at 1270-71 (citing Pioneer Hi-Bred Int'l v. Holden Found. Seeds, Inc., 35 F.3d 1226, 1242 (8th Cir.1994); Sanders v. Clemco Indus., 823 F.2d 214, 216 (8th Cir.1987)). Furthermore, because of this continuing duty to examine its subject matter jurisdiction, the court concludes that revisiting its subject matter jurisdiction cannot be foreclosed, even by a prior decision upholding subject matter jurisdiction, if the defendants come forward with some adequate basis for mounting a renewed challenge. The defendants' renewed challenge to subject matter jurisdiction is based on the Blessing decision, which was handed down only some time after this court's ruling in Laird I Thus, to the extent the Blessing decision changes the legal analysis and, more importantly, the outcome of that analysis, it certainly provides an adequate basis for the court now to reconsider subject matter jurisdiction over the plaintiffs' § 1983 claims.

Nonetheless, the court finds that, as in Laird I, the defendants still mount only a purely "legal" challenge to subject matter jurisdiction, based on Blessing and statutory dictates for federal oversight of the state agency's disability determinations, not a factual challenge based on how oversight is actually conducted. Cf. Laird I, 884 F.Supp. at 1271. As before, the court concludes that the defendants have made only a "facial" challenge to subject matter jurisdiction...

To continue reading

Request your trial
17 cases
  • E.E.O.C. v. American Home Products Corp.
    • United States
    • U.S. District Court — Northern District of Iowa
    • 13 septembre 2001
    ...basis for [a] motion to reconsider this court's grant of partial summary judgment,'" quoting this court's decision in Laird v. Stilwill, 982 F.Supp. 1345 (N.D.Iowa 1997). See AHP's Brief Regarding Intervenors at 8 (quoting Laird, 982 F.Supp. at AHP provides only a truncated statement of thi......
  • Meidinger v. Ragnone
    • United States
    • U.S. District Court — District of South Dakota
    • 26 septembre 2015
    ...of Officer Ragnone's motion to dismiss is not barred by its prior partial summary judgment decision in this case. Laird v. Stilwill, 982 F. Supp. 1345, 1354-55 (N.D. Iowa 1997) ("[A]district court's 'partial summary judgment' [is] not subject to the strictures of Rule 59(e), and the distric......
  • National Business Brokers v. Jim Williamson
    • United States
    • U.S. District Court — District of Colorado
    • 31 août 2000
    ...under Rule 59(e) or a motion for relief from judgment brought pursuant to Rule 60(b) are not satisfied. See Laird v. Stilwill, 982 F.Supp. 1345, 1353-54 (N.D.Iowa 1997). Notwithstanding the district court's broad discretion to alter its interlocutory orders, the motion to reconsider "is not......
  • Michael D. v. Gmac Mortgage Llc
    • United States
    • U.S. District Court — Western District of Missouri
    • 13 janvier 2011
    ...2008 WL 268993, at *2 n. 2 (W.D.Mo. Jan.30, 2008) (Laughrey, J.) (expressing disagreement with Elder–Keep ); Laird v. Stilwill, 982 F.Supp. 1345, 1354 (N.D.Iowa 1997) (holding that a district court's discretion to amend an interlocutory order is greater than its power to amend a final judgm......
  • Request a trial to view additional results
1 books & journal articles
  • Federal court issues
    • United States
    • James Publishing Practical Law Books Archive Social Security Issues Annotated. Vol. II - 2014 Contents
    • 3 août 2014
    ...finding that genuine issues of material facts remained. Id. at 1199. (2) In a later ruling in the same case, Laird v. Stilwill , 982 F. Supp. 1345, 1346 (N.D. Iowa 1997), the defendants filed a motion to reconsider both its ruling finding subject matter jurisdiction over the claimant’s 42 U......

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT