Sewell v. Bowen

Summary

The Eleventh Circuit reversed and remanded a decision denying Vera Sewell Social Security disability benefits. The court held that the administrative law judge improperly failed to evaluate Sewell's subjective testimony about pain after finding an underlying medical condition, bursitis, that could reasonably be expected to produce disabling pain. The court applied the pain-evaluation standard under the Social Security Disability Benefits Reform Act of 1984 and related precedent.

Holdings

1. When the record contains an objectively established medical condition that could reasonably be expected to produce the alleged disabling pain, the fact finder must evaluate the claimant's credibility regarding pain and state a reasonable basis for rejecting the testimony. The administrative law judge erred by refusing to consider Sewell's subjective pain testimony merely because the medical evidence did not corroborate the severity she alleged.
2. The Secretary's determination could not be affirmed because the administrative law judge failed to apply the governing legal standard for subjective pain evidence.

Questions Presented

1. Whether the Secretary and administrative law judge erred by failing to evaluate Sewell's subjective testimony concerning disabling pain.
2. Whether the evidence established an underlying medical condition that could reasonably be expected to produce the alleged disabling pain under the statutory pain standard.
3. Whether the Secretary's disability determination was supported by substantial evidence.

Disposition

reversed_and_remanded