Zackary A. v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of New York reviewed the Commissioner of Social Security’s denial of Zackary A.’s applications for disability and supplemental security income benefits. The court granted the plaintiff’s motion, denied the Commissioner’s cross-motion, reversed the decision, and remanded for further proceedings because the ALJ did not determine whether the plaintiff’s gender dysphoria was a severe impairment.

Holdings

1. The ALJ was required to address plaintiff's gender dysphoria and determine in the first instance whether it constituted a severe impairment. Because the ALJ's decision did not discuss or reference the condition, judicial review was frustrated and remand was necessary.
2. The court declined to reach plaintiff's remaining arguments because the ALJ's adjudication of gender dysphoria could affect the remainder of the five-step disability analysis.

Questions Presented

1. Whether the ALJ's failure to address plaintiff's diagnosed gender dysphoria and determine whether it was a severe impairment frustrated judicial review.
2. Whether the Commissioner's decision should be affirmed under the substantial-evidence and correct-legal-standard standards of review.

Disposition

reversed_and_remanded