William M., obo Jenna L. (deceased), v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Washington held that the Administrative Law Judge did not adequately consider evidence of the claimant’s continuing mental-health symptoms during periods of sobriety, custody, and residential treatment. The court reversed the denial of benefits and remanded for a determination of disability benefits from January 15, 2019, through the claimant’s death, while affirming the denial of child disability benefits for the period before January 15, 2019.

Holdings

1. The ALJ's finding that Jenna's substance use was material to the disability determination was not supported by substantial evidence because the ALJ failed to fairly and fully consider abnormal mental-health observations from individualized treatment and evaluation records during periods of custody, residential treatment, sobriety, and medication use.
2. The ALJ erred in evaluating Dr. Genthe's opinion because the ALJ improperly dismissed the opinion as a check-box assessment and failed to address material clinical observations and findings supporting the assessed limitations.
3. Remand for immediate calculation and award of partial benefits was appropriate because Jenna had died and further administrative proceedings would serve no useful purpose, while the record established disability for the period beginning January 15, 2019.
4. The denial of benefits for the period before January 15, 2019, was supported by substantial evidence, and child benefits were properly denied because disability did not begin before Jenna attained age 22.

Questions Presented

1. Whether substantial evidence supported the ALJ's finding that substance use was a material contributing factor to Jenna's disability.
2. Whether the ALJ properly evaluated the persuasiveness of Dr. Thomas Genthe's medical opinion under the applicable medical-opinion regulations.
3. Whether the record justified remand for immediate calculation and payment of partial benefits rather than further administrative proceedings.
4. Whether the denial of child disability benefits and benefits for the period before January 15, 2019, was supported by substantial evidence.

Disposition

reversed_and_remanded