A.S. v. King
- 3:24-cv-04579
- U.S. District Court · Northern District of California
- 8
A.S. v. King: the court reversed the benefits denial and remanded for further proceedings because the ALJ ignored medical opinion evidence.
A.S. may receive a new administrative disability determination. The Social Security Commissioner and the ALJ must conduct further proceedings consistent with the order, including addressing Dr. Carraway’s medical opinion at step two.
What happened
In A.S. v. King, A.S. sought review of the Social Security Commissioner’s denial of her application for child insurance benefits. The administrative law judge found that A.S. did not have a severe impairment and stopped the disability analysis at the second step.
The court ruled that the administrative law judge had to address Dr. Kristen Carraway’s report, which discussed A.S.’s diagnoses, symptoms, and difficulty completing tasks. The court rejected the Commissioner’s arguments that the report was vague, concerned only A.S.’s current functioning, or was not relevant to the claimed disability period.
The court granted A.S.’s request for remand, reversed the Commissioner’s final decision, and remanded the case for further proceedings. The administrative law judge must specifically address Dr. Carraway’s opinion at step two and consider other issues A.S. raised. The opinion does not identify the judge by name; it was issued by the court.
The detailed version
- A.S. v. King · No. 3:24-cv-04579
- Feb. 18, 2025
Background
A.S. applied for child insurance benefits based on an alleged disability period from July 31, 2003, to July 31, 2007. The administrative law judge (ALJ) denied the application on August 25, 2023, finding at step two of the Social Security Administration’s five-step disability evaluation that A.S. did not have a severe impairment or combination of impairments. The Appeals Council declined to disturb that decision, making it final.
A.S. asked the district court to remand the case. The request focused on the ALJ’s failure to address a May 4, 2009 report by Dr. Kristen Carraway, a licensed psychologist who treated A.S. from April 1, 2008, through August 5, 2008. The report discussed obsessive-compulsive disorder, anxiety, other diagnoses, symptoms affecting daily living and task completion, and a discrepancy between A.S.’s intellect and ability to function.
Court’s Analysis
The court explained that 20 C.F.R. § 404.1527(c) requires an ALJ to evaluate every medical opinion received. It determined that Dr. Carraway was an acceptable medical source and that her report qualified as a medical opinion because it addressed A.S.’s symptoms and how they resulted in impairments.
Although the ALJ mentioned some information consistent with Dr. Carraway’s report, the ALJ did not explicitly accept or reject the opinion. The court held that this was legal error. The court also found Dr. Carraway’s opinion relevant to A.S.’s overall disability claim, despite the Commissioner’s arguments that the report was vague, concerned only current functioning, or was not probative of the alleged disability period.
The court further held that the error was not harmless. Because Dr. Carraway’s opinion addressed diagnoses and their effects on A.S.’s abilities, the court could not conclude that considering it would have made no difference to the disability determination. The court therefore did not reach A.S.’s remaining arguments about the sufficiency of the administrative record.
Disposition
The court GRANTED A.S.’s request for remand, REVERSED the Commissioner’s final decision, and REMANDED the case to the ALJ for further proceedings consistent with the order. On remand, the ALJ must specifically address Dr. Carraway’s medical opinion at step two, consider the other issues raised in A.S.’s briefing, and modify any ensuing decision as appropriate. The clerk was ordered to terminate and close the case. The opinion does not provide the judge’s name.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.