Cooper v. Saul

Background

Gary Emmett Cooper sought judicial review of a decision denying his claim for Social Security disability benefits. The court considered both parties’ motions for summary judgment, which ask the court to decide the case based on the record without a trial.

Reasons for the ruling

The court held that the administrative law judge’s residual functional capacity determination—the assessment of what Cooper could still do despite his impairments—was not supported by substantial evidence. The administrative law judge relied mainly on Dr. Rana, a state consultative examiner whose examination occurred before Cooper suffered injuries after wandering into traffic in January 2016. The administrative law judge reasoned that opinions based on examinations before that incident were less reliable than opinions based on later examinations, but did not account for the fact that Dr. Rana’s examination also occurred before the incident. The court found that the administrative law judge did not provide additional reasons for giving Dr. Rana’s opinion the greatest weight.

The court separately held that the administrative law judge did not give legally adequate reasons for rejecting the opinion of Cooper’s treating physician, Dr. Ali. Dr. Ali treated Cooper for an extended period after the January 2016 incident. The administrative law judge said Dr. Ali’s opinion conflicted with the state consultants’ opinions, but the court noted that those consultants had assessed Cooper before the incident. The administrative law judge also cited Dr. Ali’s treatment notes, but the notes were almost entirely illegible. Although words such as “mild,” “moderate,” and “severe” could be read, it was unclear which conditions they described or how they contradicted Dr. Ali’s later assessment of significant physical limitations. The court concluded that these were not sufficiently specific and legitimate reasons for rejecting the treating physician’s opinion.

Additional concerns identified by the court

The court noted, but did not decide, concerns about Cooper’s psychiatric condition. The administrative law judge’s decision and medical records suggested that Cooper might meet the listing for schizophrenia, and the records described delusions and serious limitations in interacting with others. The court also questioned whether the administrative law judge violated due process by treating Cooper’s late appearance at the hearing as a constructive waiver without asking whether he had good cause. The court did not resolve either issue because neither was presented in the appeal.

Disposition

Judge Vince Chhabria granted Cooper’s motion for summary judgment and denied the Commissioner’s motion for summary judgment. The court remanded the action for further proceedings. It expressly found that this was not a case warranting a remand for an award of benefits, so it did not order benefits to be awarded immediately.