Monet v. Berryhill
280 F. Supp. 3d 35
| D.D.C. | 2017Background
- Melinda Monet sued the Acting Commissioner of Social Security seeking recovery of Social Security benefits the SSA withheld.
- The court initially dismissed for lack of subject-matter jurisdiction, but Monet filed motions prompting further inquiry; the court ordered the SSA to answer questions about withheld amounts.
- SSA conceded it had continued to withhold monthly benefits from Oct 2006–June 2016 despite an ALJ’s March 2008 waiver of an overpayment; SSA paid Monet $10,865 (the erroneously withheld amount) after the court’s inquiry.
- Separately, SSA withheld benefits March–Oct 2006 (approximately $8,715) based on 42 U.S.C. § 402(x)(1)(A)(ii)(III), because Judge Richard Leon found Monet incompetent to stand trial and ordered her confined at the Federal Medical Center, Carswell.
- Monet argued withholding was improper because she was a detainee (not incompetent) and because she was not “hospitalized in a suitable facility at public expense.” The court examined Judge Leon’s orders and record from the criminal case.
- The court concluded the SSA’s payment of $10,865 mooted that claim, but upheld the March–Oct 2006 withholding under § 402(x)(1)(A)(ii)(III); the court vacated its prior July 25, 2017 dismissal and entered final judgment for Defendant, granted IFP on appeal, and ordered a sealed criminal-court document placed on the civil docket.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether SSA improperly withheld benefits that an ALJ waived | Monet: SSA erred by continuing monthly withholdings after ALJ waived overpayment | SSA: Administrative error—ALJ waived overpayment but SSA failed to implement; SSA later paid withheld amount | Moot as to $10,865; SSA paid Monet that amount |
| Whether SSA validly withheld benefits under 42 U.S.C. § 402(x)(1)(A)(ii)(III) due to confinement for incompetency | Monet: She was merely a pretrial detainee, not incompetent, so § 402(x) does not apply | SSA: Judge Leon found Monet incompetent and ordered confinement; § 402(x) disqualifies benefits during such confinement | Held: Withholding from Mar–Oct 2006 proper under § 402(x) |
| Whether Monet was “confined by court order in an institution at public expense” | Monet: She was not hospitalized in a suitable public facility as required by Judge Leon’s order | SSA: Monet was resident at Federal Medical Center, Carswell under court orders—thus confined in an institution at public expense | Held: Monet was confined at Carswell by court order; statutory condition satisfied |
| Procedural relief and final disposition | Monet sought reconsideration and leave to amend; also appealed | SSA provided supplemental responses; court treated the filings akin to a summary-judgment motion and resolved the merits | Court denied motions to modify/reconsider except as moot for paid amount, denied amended complaint, granted IFP on appeal, vacated earlier dismissal and entered judgment for Defendant |
Key Cases Cited
- Hoai v. Vo, 935 F.2d 308 (D.C. Cir. 1991) (district court may consider pending Rule 60(b)-type motion while appeal is pending)