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Middle District Pennsylvania Memorandum Reveals What To Expect in a Social Security Review

If you are unable to work as a result of a disability, you may qualify for Social Security Disability Insurance (SSDI) or Supplemental Security Income (SSI).  In order to receive these benefits, you must be unable to work as a result of a medical condition that will last more than a year or result in death.  For SSDI, you must have worked before, but employment history is not necessarily required for SSI. 

A District Court memorandum, Owens v. Social Security Administration et al., reviewed a decision of the Commissioner of Social Security denying Owens’ claim for SSDI and SSI benefits.  The disabled woman qualified for benefits in June 2010 and filed her application for benefits, claiming she became disabled on January 11, 2010, which met the requirement that the disability occur before the date of qualification.  The woman was diagnosed with multiple impairments, including breast abscesses, left hip bursitis, major depressive disorder, PTSD, bipolar disorder, and polysubstance dependence.  The case was heard by an administrative law judge, who denied her applications.  The Appeals Council also declined to grant review.  The disabled woman appealed, and the district court remanded the case for further proceedings

The disabled woman was hospitalized multiple times from April 2010 to October 2011.  During this period, she was diagnosed with polysubstance dependence and frequently expressed suicidal ideations.  It was also during this time that she was diagnosed with bipolar disorder and PTSD due to extreme guilt that her past substance abuse caused her sons to be disabled.  The penultimate diagnosis stated that she had “occupational and social impairment with reduced reliability and productivity.”

In May 2011, the woman’s mental residual functional capacity was assessed, and it was determined that she would likely miss more than three days of work each month and have limited ability to accept instructions and respond appropriately to criticism from supervisors, interact with her coworkers appropriately, and understand, remember, and carry out detailed instructions. 

In the memorandum, the district court reiterated the requirements under 42 U.S.C. § 405{g).  The Code states that the district court is obligated to uphold the findings of the Commissioner if they are supported by substantial evidence, or evidence that is relevant and that a reasonable mind would accept as adequate to support a conclusion.  The evidence submitted must be taken as a whole, and the Commissioner is required to show what evidence was accepted, what was rejected, and the reasons for rejecting certain evidence.  The Commissioner must follow the outlined process, which looks at whether a claimant is engaged in substantial gainful activity, has an impairment that is severe or a combination of impairments that are collectively severe, has an impairment or combination of impairments that meets or equals the requirements of a listed impairment, or has the residual functional capacity to return to prior work, and if not, whether it is possible to work somewhere else in the national economy.

While the District Court did not think all of the ALJ’s findings were unreasonable, the court was concerned with the shifting weight attributed to the physician assessing the woman’s ability to function in the workplace.  The Court distinguished the woman’s test results, which revealed an ability to moderately function in some ways, from the evidence taken as a whole that the woman would experience regular problems functioning in the workplace.  The court ultimately concluded that the Commissioner’s decision was not supported by substantial evidence.

Our attorneys at Needle Law Firm have the Social Security knowledge and experience you need in filing your claim for benefits.  If you or a family member needs assistance with a claim, call our office today at 570-344-1266.

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