James K. v. Commissioner of Social Security

Summary

The U.S. District Court for the Eastern District of Washington grants Plaintiff James K.’s opening brief and denies the Commissioner of Social Security’s brief in a judicial review of a disability-benefits decision. The court upholds the administrative law judge’s finding that drug addiction and alcoholism were material to disability, but remands for further consideration of the supportability and consistency factors relating to certain medical opinions.

Holdings

1. The ALJ's finding that Plaintiff's drug addiction and alcoholism were material to the disability determination was supported by substantial evidence.
2. The ALJ erred by failing to address the required supportability and consistency factors for Dr. Anderson's opinion and by failing to address supportability for Dr. Garner's opinion.
3. The ALJ reversibly erred by failing to identify specifically which portions of Plaintiff's mental symptom testimony were rejected and what evidence undermined those portions.
4. The ALJ did not err in finding that Plaintiff failed to satisfy the Paragraph C criteria of the applicable mental-disorder listings.

Questions Presented

1. Whether the ALJ properly found that Plaintiff's drug addiction and alcoholism were material to the disability determination.
2. Whether the ALJ properly evaluated the medical opinion evidence from Dr. Genthe, Dr. Anderson, and Dr. Garner.
3. Whether the ALJ properly evaluated Plaintiff's subjective symptom testimony concerning his mental impairments.
4. Whether the ALJ properly considered the Paragraph C criteria of Listings 12.04, 12.06, 12.11, and 12.15.

Disposition

reversed_and_remanded