Jarrett J. v. Saul
- Robert Illman
- 1:20-cv-01201
- U.S. District Court · Northern District of California
- 14
In Jarrett J. v. Saul, Judge Illman granted Jarrett J.’s summary judgment motion, denied Saul’s, and remanded the disability-benefits case for further proceedings.
Jarrett J. and the Social Security Administration; the case returns to the agency for further proceedings, with instructions to credit Jarrett J.’s pain testimony and his employer’s statements as true.
What happened
In Jarrett J. v. Saul, Jarrett J. asked the court to review the denial of his applications for disability insurance benefits and supplemental security income. He argued that the administrative law judge improperly rejected his testimony about chronic pain and failed to consider a letter from his employer describing his work limitations.
The court ruled that the administrative decisions did not adequately explain why Jarrett J.’s pain testimony was rejected and did not address his employer’s statements. The court treated both the testimony and the employer’s statements as true under the governing rules, but found that further administrative proceedings were needed to determine whether the combined evidence established disability.
Judge Illman granted Jarrett J.’s motion for summary judgment, denied the Commissioner’s cross-motion, and remanded the case for further proceedings. On remand, the administrative law judge must credit Jarrett J.’s pain and symptom testimony and the employer’s statements as true.
The detailed version
- Jarrett J. v. Saul · No. 1:20-cv-01201
- Robert Illman
- Sept. 17, 2021
Background
Jarrett J. sought judicial review of the denial of his applications for disability insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. He alleged disability beginning December 12, 2013, after a December 2013 slip-and-fall accident that caused spinal and head injuries.
The administrative law judge found that Jarrett J. had severe impairments including cervical spondylosis, lumbar degenerative disc disease, and obesity. The administrative law judge determined that Jarrett J. could perform light work with additional restrictions, could not return to his past work as a line cook, but could perform other jobs such as cashier, storage-facility rental clerk, or furniture-rental consultant. The Appeals Council issued a later decision that largely adopted those findings and also concluded that Jarrett J. was not disabled.
Jarrett J. argued that the administrative law judge and Appeals Council improperly rejected his testimony about the limiting effects of his pain. He also argued that they failed to consider or even mention a letter from his employer stating that Jarrett J. could work only three to four hours per day on a few days each week because of his physical pain.
Court’s analysis
The court reviewed the agency’s decision under the substantial-evidence standard, which asks whether relevant evidence supports the agency’s factual findings, and whether the agency applied the correct legal rules.
The court held that the administrative law judge did not provide sufficiently specific, clear, and convincing reasons for rejecting Jarrett J.’s testimony about his pain and limitations. The court found that the administrative law judge’s reasoning relied largely on a general statement that the testimony was inconsistent with the evidence and on the fact that Jarrett J. worked part time. The court characterized that reasoning as speculative and circular. The Appeals Council adopted the administrative law judge’s reasoning without correcting the problem.
The court also held that the administrative law judge and Appeals Council failed to consider the employer’s letter. An administrative law judge must give specific reasons related to each lay witness when rejecting that witness’s testimony. Because the employer’s statements were not mentioned or evaluated, the court credited them as true as a matter of law. The court likewise credited Jarrett J.’s pain and symptom testimony as true.
Remand
The court declined to order an immediate award of benefits. It found that the record was poorly developed and that it remained unclear whether Jarrett J.’s testimony, the employer’s statements, and the medical evidence together would conclusively establish disability. The court therefore remanded for further administrative proceedings rather than directing payment of benefits.
On remand, the administrative law judge may not accept or reject the portions of Jarrett J.’s testimony and the employer’s statements that were before the court and were credited as true.
Disposition
Jarrett J.’s motion for summary judgment was granted. The Commissioner’s cross-motion for summary judgment was denied. The case was remanded for further proceedings consistent with the opinion.
Read the full 14-page opinion on CourtListener, the free public archive maintained by the Free Law Project.