Tayag v. Commissioner of Social Security
- Beth Freeman
- 5:25-cv-06785
- U.S. District Court · Northern District of California
- 19
In Arthur Tayag v. Commissioner, Judge Freeman granted summary judgment, rejected the disability decision, and remanded for further proceedings.
Arthur Tayag’s disability-benefits claim returns to the Social Security Administration for further proceedings. The court did not order an immediate award of benefits.
What happened
Arthur Tayag v. Commissioner of Social Security concerns Tayag’s challenge to the denial of his application for disability insurance benefits. He sought benefits for a closed period ending when he returned to work in May 2022. The administrative law judge found that Tayag had several physical and mental impairments but could perform other jobs.
The court found that the administrative law judge did not adequately evaluate medical evidence about Tayag’s memory, attention, problem-solving, depression, and anxiety. The judge also failed to give specific reasons for rejecting Tayag’s testimony and did not properly evaluate statements from his spouse and former supervisor. The court did not separately address the challenge to the vocational expert’s testimony because it depended on those other errors.
Judge Freeman granted Tayag’s motion for summary judgment, denied the administrative law judge’s determination, and remanded the case to the Social Security Administration. The court did not order an immediate award of benefits because additional issues remained, including how to evaluate the neuropsychological evidence and whether further development was needed concerning Tayag’s later employment.
The detailed version
- Tayag v. Commissioner of Social Security · No. 5:25-cv-06785
- Beth Freeman
- Sept. 8, 2026
Background
Arthur Tayag appealed the Commissioner of Social Security’s denial of his application for disability insurance benefits under Title II of the Social Security Act. Tayag alleged disability beginning October 29, 2018, and later requested a closed disability period ending May 4, 2022, when he returned to work as a maintenance worker.
Tayag had a history of traumatic brain injury, headaches, convergence insufficiency, degenerative disc disease, hand osteoarthritis, psoriasis, major depressive disorder, generalized anxiety disorder, and attention deficit hyperactivity disorder. The administrative law judge (ALJ) found these impairments severe but determined that Tayag could perform medium work with limitations, including the ability to understand, remember, and carry out simple instructions. Relying in part on vocational-expert testimony, the ALJ found that jobs such as cleaner, hand packager, and store laborer existed in significant numbers and denied benefits.
Court’s Analysis
The court concluded that the ALJ’s residual functional capacity determination was not adequately supported. In evaluating Dr. Gary Miles’s neuropsychological evaluation, the ALJ relied on purportedly minimal mental-status findings, improvement, and daily activities. Those reasons addressed only whether Dr. Miles’s opinions were consistent with the rest of the record. The ALJ did not address whether the neuropsychological testing itself supported Dr. Miles’s conclusions and recommendations, including findings of severe or moderate deficits in memory, processing speed, attention, and concentration. The court held that this error was not harmless.
The court also found that the ALJ did not identify substantial evidence supporting the decision to discount speech pathologist Jeri C. Frakes’s finding of moderately severe impairment in problem-solving. The ALJ referred generally to minimal mental-status findings and good daily activities but did not identify specific evidence concerning problem-solving that contradicted Frakes’s evaluation. The ALJ also relied on Tayag’s later maintenance work without explaining how that work showed greater problem-solving ability during the period addressed by Frakes’s evaluation.
The court further held that the ALJ improperly rejected Tayag’s subjective symptom testimony. The ALJ made general statements that Tayag’s symptoms were inconsistent with the record, treatment history, mental-status findings, and daily activities, but did not identify which testimony was being rejected or connect particular testimony to particular evidence. The court also noted that the ALJ did not explain why activities such as exercise, travel, setting up his daughter’s computer, and watching television conflicted with Tayag’s claimed limitations. The ALJ’s reliance on Tayag’s return to work did not resolve whether he was disabled during the earlier closed period.
The court found similar errors in the treatment of statements from Tayag’s spouse, Ma Ives Tayag, and former supervisor, Darlito Gacuya. The ALJ relied on the same incomplete assessment of the medical record and failed to account for Dr. Miles’s neuropsychological findings. The ALJ also inaccurately stated that Ma Ives Tayag said Tayag did not need reminders, when her statement said the opposite: that he could not focus, was forgetful, and needed reminders. The court held that the lay-witness evidence had to be reconsidered in the context of the entire administrative record.
The court did not separately decide Tayag’s challenge to the vocational expert’s hypothetical questions because that argument depended on the preceding errors concerning the medical opinions, Tayag’s testimony, and the lay-witness statements.
Remedy and Disposition
Tayag requested an immediate award of benefits. The court declined to do so because unresolved issues remained concerning the proper weight to give Dr. Miles’s neuropsychological evaluation and whether the record needed further development concerning Tayag’s later job. Instead, the court ordered further administrative proceedings.
The court GRANTED Tayag’s motion for summary judgment, DENIED the ALJ’s determination, and REMANDED the case to the Commissioner of Social Security.
Read the full 19-page opinion on CourtListener, the free public archive maintained by the Free Law Project.