Reed v. Frank J. Bisignano

Background

Mark Anthony Reed sought judicial review of the Commissioner of Social Security’s decision that he was not disabled and was not eligible for disability benefits under Title XVI of the Social Security Act during the period from January 7, 2015, through July 27, 2017. Reed had been receiving benefits for the period beginning July 27, 2017, but challenged the denial for the earlier period.

The administrative law judge found that Reed had several severe impairments, including degenerative disc disease, osteoarthritis, post-traumatic glaucoma, post-traumatic stress disorder, affective disorder, severe recurring major depressive disorder with psychotic features, and polysubstance abuse in partial remission. The judge nevertheless found that Reed could perform light work and was not disabled. Reed had previously obtained a remand in a related proceeding. After additional hearings, the same administrative law judge issued another unfavorable decision on March 15, 2022.

Legal Standard

The court reviewed the administrative law judge’s decision to determine whether it was supported by substantial evidence and whether it contained legal error. Substantial evidence means more than a mere scintilla but less than a preponderance—relevant evidence that a reasonable person might accept as adequate to support the conclusion.

When a claimant has medically supported impairments that could cause the alleged symptoms, an administrative law judge must give specific, clear, and convincing reasons for rejecting the claimant’s testimony about the severity of those symptoms.

Court’s Analysis

The court found that the administrative law judge did not meet that standard. The judge summarized Reed’s medical records and identified two claimed inconsistencies: Reed’s statements about needing help with personal care and household chores, and his statements about being able to read only simple words and needing help with forms.

The court concluded that these points did not adequately contradict Reed’s testimony. Reed’s ability to perform basic hygiene, prepare simple food, study an Alcoholics Anonymous book, or complete a history form did not resolve whether he could stand and walk long enough to perform light work.

Reed testified that he could stand for only a short time, walk for about a minute before needing to sit or lean on something, and sometimes stumbled and fell because of problems with his lower back, knees, and nerves in his legs. The administrative law judge did not address this testimony or explain clearly why it was rejected. The court found that this evidence directly conflicted with the finding that Reed could stand or walk intermittently for about six hours during an eight-hour workday.

Because the administrative law judge improperly discounted Reed’s testimony, the resulting assessment of his work capacity also failed to account for all of his limitations. The court did not need to consider Reed’s remaining arguments about the weight given to medical opinions.

Remedy and Disposition

The court determined that a remand for calculation and award of benefits, rather than another administrative proceeding, was appropriate. It found that the record was fully developed, the reasons for rejecting Reed’s testimony were legally insufficient, and the administrative law judge would be required to find Reed disabled if the improperly rejected evidence were accepted as true. The court also cited the significant delay since Reed first applied for benefits in 2015.

The court GRANTED Reed’s motion for summary judgment, DENIED the Commissioner’s motion for summary judgment, REVERSED the Commissioner’s final decision, and REMANDED for calculation and award of benefits.