Angel H. v. Commissioner of Social Security
- Gabriel Gorenstein
- 1:25-cv-00131
- U.S. District Court · Southern District of New York
- 16
In Angel H. v. Commissioner, Judge Jones granted Angel H.’s motion and remanded the benefits case for more record development.
Angel H.’s claim for Supplemental Security Income benefits will return to the Social Security Administration for further proceedings; the order did not require an award of benefits.
What happened
In Angel H. v. Commissioner of Social Security, Angel H. asked the court to review the denial of Supplemental Security Income benefits. The administrative law judge found severe seizure, bipolar, and anxiety disorders but concluded that Angel H. could perform available work.
The court found that the administrative law judge had not adequately developed the evidence about Angel H.’s mental functioning. Although several medical professionals identified significant limitations, the administrative law judge rejected or discounted each opinion and did not obtain an assessment from the treating mental-health provider identified at the hearing.
Judge Gary R. Jones granted Angel H.’s motion for judgment on the pleadings and remanded the case for further administrative proceedings. The court directed entry of final judgment for Angel H.; it did not decide that benefits must be awarded.
The detailed version
- Angel H. v. Commissioner of Social Security · No. 1:25-cv-00131
- Gabriel Gorenstein
- Oct. 6, 2025
Background
Angel H. applied for Supplemental Security Income benefits in December 2021, alleging disability beginning July 13, 2018. The Social Security Administration denied the application initially and on reconsideration. After a hearing, Administrative Law Judge Mark Solomon denied the application on January 25, 2024. The Appeals Council declined review on November 15, 2024, making the administrative law judge’s decision the Commissioner’s final decision.
The administrative law judge found that Angel H.’s seizure disorder, bipolar disorder, and anxiety disorder were severe impairments. The judge nevertheless found that Angel H. could perform a full range of work at all exertional levels, subject to restrictions including no climbing ladders, ropes, or scaffolds; no commercial driving; no work at unprotected heights or with hazardous machinery; and work involving simple instructions, simple decisions, routine changes, and frequent contact with others. Because a vocational expert identified jobs existing in significant numbers in the national economy, the administrative law judge found Angel H. not disabled.
Court’s analysis
The court reviewed whether substantial evidence supported the Commissioner’s decision and whether the correct legal standards were applied. It focused on the administrative law judge’s duty to develop the record. That duty requires the administrative law judge to investigate the facts and develop arguments both for and against granting benefits, even when the claimant has a lawyer. The duty is heightened when the claimant alleges mental impairments.
The record included several assessments addressing Angel H.’s mental functioning. Treating neurologist Dr. Manjeet Dhallu stated that Angel H. could not perform even low-stress jobs and would be absent about one day per month. Consultative psychiatrist Dr. Joshua Goldstein identified moderate or mild limitations in several areas, including following instructions, concentration, maintaining a routine, attendance, and responding to hazards. State-agency consultant Dr. M. D’Ortona also identified moderate limitations in several mental-functioning areas.
The administrative law judge did not find any of these opinions fully persuasive. The court concluded that the judge then improperly determined the extent of Angel H.’s mental limitations without obtaining a functional assessment from the treating mental-health provider Angel H. identified at the hearing as “Kathy Labich [phonetic].” The record contained no such assessment, and the court found no evidence that the administrative law judge sought one. The court also rejected the argument that Angel H.’s lawyer’s failure to submit additional evidence relieved the administrative law judge of the duty to develop an obviously incomplete record.
Ruling and effect
Judge Gary R. Jones held that the missing evidence prevented a fair adjudication of the benefits application. The court granted Angel H.’s Motion for Judgment on the Pleadings and remanded the case for further administrative proceedings consistent with the decision and order. The Clerk was directed to enter final judgment in Angel H.’s favor and close the case. The order did not award benefits or decide the ultimate entitlement to benefits.
Read the full 16-page opinion on CourtListener, the free public archive maintained by the Free Law Project.