Sellari v. Bisignano

Summary

The United States District Court for the Western District of Pennsylvania reviews the denial of Christopher Joseph Sellari’s application for Social Security disability insurance benefits. The court concludes that the Administrative Law Judge did not adequately develop and consider the evidence underlying the Department of Veterans Affairs’ 100% disability determination, particularly regarding PTSD, anxiety, and alcohol dependence. The court denies the parties’ summary judgment motions and remands the case to the Commissioner for further proceedings.

Holdings

1. The ALJ failed to fulfill the duty to develop the record by not obtaining the complete VA records supporting its 100% disability determination for plaintiff's mental health conditions.

Questions Presented

1. Whether the ALJ failed to properly develop the record regarding the VA's 100% disability determination and its underlying documentation for plaintiff's mental health limitations.
2. Whether the ALJ's decision is supported by substantial evidence regarding plaintiff's PTSD, anxiety, alcohol dependence, and polycythemia.

Disposition

remanded