Williams v. Commissioner of Social Security

Background

Marshaun Felix Williams challenged a Social Security Administration administrative law judge’s decision denying his claim for Supplemental Security Income under Title XVI of the Social Security Act. The parties filed cross-motions for summary judgment, which asks the court to decide whether the administrative decision should stand based on the record.

Williams had previously received Supplemental Security Income for bipolar disorder in 2003. His benefits were terminated while he was incarcerated from 2005 to 2010. He applied for benefits on March 18, 2014.

The Social Security Administration’s September 4, 2014, notice stated that Williams’s condition was not disabling before age 22. That notice also referred to disabled-child Social Security benefits and included rules for both those benefits and Supplemental Security Income. Williams requested reconsideration, identifying his claim as one for Supplemental Security Income. The December 2, 2014, reconsideration notice stated that the first decision was correct but described the issue as whether his condition was severe enough to prevent him from working.

Williams then requested an administrative hearing. His request expressly asserted that the September notice and December notice conflicted and that the denial was based on his failure to prove disability before age 22. The hearing notice stated that the administrative law judge would consider Williams’s March 18, 2014, application for Supplemental Security Income.

At the October 14, 2016, hearing, Williams appeared with his father, Kevin Williams, who acted as his representative. Williams and his father repeatedly explained that they understood the case to concern medical evidence from before Williams turned 22. The administrative law judge instead stated that the relevant disability period began on February 28, 2014. The judge did not explain why the relevant period had changed from the one identified in the earlier notices, and responded only “Okay” to repeated objections on that point.

The administrative law judge issued a decision on March 2, 2017, finding that Williams had not been disabled since February 28, 2014. The decision also stated that Williams’s representative had said the record was complete, although the district court found that statement inconsistent with the hearing transcript.

Court’s Analysis

The court described the appeal as unusual because Williams appeared unclear, and possibly confused, about which claims and time period were being considered. The court noted that Williams’s application referred to Supplemental Security Income and benefits under other Social Security Administration programs, and that the initial denial referred to disability before age 22. The court also noted that Williams later focused on Supplemental Security Income, and that the agency thereafter addressed that claim only.

The court held that the time-period problem independently required a remand. Williams had a reasonable basis, grounded in the agency’s own documents, to believe that his Supplemental Security Income claim had been denied because he had not shown disability before age 22. The agency did not clearly communicate that the administrative law judge would instead consider only the period from 2014 through the 2016 hearing.

The court found a substantial concern that Williams did not receive constitutionally adequate notice and a meaningful opportunity to be heard. It also found that the administrative law judge failed to fulfill the independent duty to fully and fairly develop the record. That duty applies to represented and unrepresented claimants, and requires particular care when a claimant is represented by a lay person rather than an attorney.

The court rejected the idea that leaving the record open for two weeks cured the problem. In the court’s view, two weeks was not enough under the circumstances because the relevant period had shifted by more than a decade without adequate notice. The record also raised doubts about whether the record was meaningfully kept open during that time.

Disposition

The case was remanded to the Social Security Administration for further proceedings consistent with the order. The court declined to address the parties’ other arguments concerning the administrative law judge’s decision. The remand resolved the court’s review based on notice, opportunity to be heard, and development of the record; it did not decide whether Williams was ultimately entitled to disability benefits.