Helen J. A. v. Saul
- Robert Illman
- 1:19-cv-04626
- U.S. District Court · Northern District of California
- 7
In Helen J. A. v. Saul, Judge Illman remanded the disability-benefits case because the administrative record was inadequate for review.
Helen J. A. and the Commissioner of Social Security; the case returns to the administrative law judge for further proceedings, and the opinion does not award benefits.
What happened
Helen J. A. asked the court to review an administrative law judge’s decision denying her disability insurance and supplemental security income benefits. The administrative law judge considered the period from July 31, 2015, through November 13, 2017, after finding that her later work was substantial gainful activity.
The court found that the hearing and decision were not properly focused on that 27-month period. Because much of the evidence concerned later activities or lacked dates, the court could not determine whether the findings from the second step onward were supported by sufficient evidence.
Judge Illman granted Helen J. A.’s motion for summary judgment, denied the Commissioner’s cross-motion, and remanded the case for further proceedings. The administrative law judge must develop a proper record, including seeking a revised opinion from treating physician Matthew Joseph and holding a second hearing focused on the relevant period; the court did not decide Helen J. A.’s remaining arguments.
The detailed version
- Helen J. A. v. Saul · No. 1:19-cv-04626
- Robert Illman
- Mar. 23, 2021
Background
Helen J. A. sought judicial review of an administrative law judge’s decision denying her applications for disability insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. The Appeals Council denied review, making the administrative law judge’s decision the final decision of the Commissioner for purposes of district-court review.
Helen J. A. alleged that her disability began on July 31, 2015. The administrative law judge found that she had been engaged in substantial gainful activity since November 13, 2017, and stated that the decision would focus on the period from July 31, 2015, through that date. The administrative law judge found several severe impairments, including diabetes, diabetic eye conditions, glaucoma, cataracts, and diabetic peripheral neuropathy. The administrative law judge determined that Helen J. A. could perform a limited range of light work and could perform past work as a receptionist, secretary, or administrative clerk. The administrative law judge therefore found that she was not disabled through August 14, 2018.
Arguments and Analysis
Both parties moved for summary judgment. Helen J. A. raised three arguments: that her leg needed to be elevated twelve rather than ten inches during part of the workday; that pain affected her attention and concentration; and that the administrative law judge improperly rejected some of her pain and symptom testimony. She did not challenge the finding that her employment beginning in November 2017 constituted substantial gainful activity.
The court concluded that the hearing and the administrative law judge’s decision were not adequately focused on the 27-month period from July 31, 2015, through November 13, 2017. The hearing questions were not limited to that period. The decision likewise relied on activities occurring after that period or described events and conditions without identifying when they occurred. The medical-opinion discussion had the same problem.
Because the record was not developed around the relevant period, the court could not determine whether the administrative law judge’s findings from Step Two forward were supported by substantial evidence. In Social Security cases, the administrative law judge has an independent duty to fully and fairly develop the record and investigate relevant facts. The court held that this duty was not satisfied here.
Disposition
The court ordered a remand for further proceedings. On remand, the administrative law judge must contact Helen J. A.’s treating physician, Matthew Joseph, M.D., to seek a revised opinion about her functional limitations and must conduct a second hearing focused on the 27-month disability period. The court declined to decide Helen J. A.’s remaining arguments because they could be addressed on remand and might be affected by the further proceedings.
The court granted Helen J. A.’s motion for summary judgment, denied the Commissioner’s cross-motion, and remanded the case pursuant to the stated instructions. Judge Robert M. Illman signed the order.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.