Scotty H. v. Frank Bisignano

Summary

The United States District Court for the Eastern District of Missouri reviews the denial of Scotty H.’s applications for Disability Insurance Benefits and Supplemental Security Income. The court reverses the Commissioner’s decision and remands for further proceedings, addressing the administrative law judge’s failure to fully develop the record concerning the plaintiff’s treating psychiatrist and the support for the residual functional capacity finding.

Holdings

1. The ALJ failed to fulfill the independent duty to fully and fairly develop the record because the record plainly lacked approximately five years of treatment notes from Plaintiff's identified treating psychiatrist, and the ALJ could not reasonably rely on counsel's inaccurate representation that the submitted records were complete.
2. Reversal and remand under sentence four of 42 U.S.C. § 405(g) was warranted because the missing psychiatric treatment records left a crucial issue undeveloped and prevented a reliable determination of the effect of Plaintiff's impairment on his ability to work.

Questions Presented

1. Whether the ALJ fulfilled the independent duty to fully and fairly develop the administrative record when the record plainly lacked years of treatment notes from the claimant's identified treating psychiatrist.
2. Whether the Commissioner's decision should be reversed and remanded because the undeveloped record prevented a reliable assessment of the claimant's mental limitations and residual functional capacity.

Disposition

reversed_and_remanded