Summary
This is a United States District Court order resolving cross-motions for remand in a Social Security disability benefits appeal. The court determined that the Administrative Law Judge erred in weighing medical opinion evidence but concluded the record was sufficiently developed to warrant an immediate award rather than further administrative proceedings. Accordingly, the court remanded the case to the Commissioner of Social Security for the calculation and payment of benefits.
Topics
Practice areas
Questions Presented
- Whether the ALJ erred in evaluating medical opinion evidence sufficient to require remand for calculation of benefits
- Whether the court should remand for further proceedings or for an award of benefits
Holdings
- The court holds that the ALJ erred in evaluating the medical opinion evidence and, because the record is fully developed, the court may remand for calculation of benefits rather than further proceedings.
Key quotations
“Remand for an award of benefits is appropriate. This record is well‑developed and a number of examining sources have opined as to disabling limitations.” (end)
Factual background
Plaintiff Kevin O. suffers from multiple severe physical and mental impairments, including Klinefelter syndrome, diabetes, peripheral neuropathy, vision loss, ADHD, borderline intellectual function, depressive and anxiety disorders, schizoaffective disorder, and polysubstance use. The ALJ found he could perform only light work with numerous limitations and denied benefits.
Procedural history
The plaintiff filed for SSDI benefits in 2016, was denied at initial and reconsideration levels, and after multiple ALJ hearings the ALJ denied benefits. The Appeals Council denied review, and the plaintiff sued. The district court previously remanded for further proceedings; the commissioner now seeks another remand, while the plaintiff seeks remand for calculation of benefits.
Remand instructions
Calculate and award benefits from the alleged disability onset date.