Ramsey v. Saul

Background

Yves Ramsey brought an action under 42 U.S.C. §§ 405(g) and 1383(c)(3) seeking judicial review of the Social Security Administration’s termination of her disability benefits. She had been found disabled in 2009 because of limitations related to an affective mood disorder and learning disorder. After a continuing disability review, the agency determined that her disability had ended because of medical improvement as of May 16, 2016. An administrative law judge later upheld the termination, and the Appeals Council denied review.

Ramsey moved for summary judgment, arguing that the administrative law judge erred by rejecting opinions from her treating and examining clinicians, discounting her reports about her symptoms, finding medical improvement, determining her residual functional capacity, and relying on incomplete vocational-expert testimony. The government did not timely oppose the motion. After Ramsey moved for default judgment, the government conceded all five alleged errors and agreed that Ramsey was entitled to summary judgment. It opposed default judgment and argued that the case should be remanded for further proceedings rather than for an award of benefits.

Court’s analysis

The court explained that a remand for an award of benefits is appropriate when the record is fully developed, the administrative law judge failed to give legally sufficient reasons for rejecting evidence, and crediting that evidence as true would require a finding that the claimant is disabled. The court found that the government’s concessions satisfied the latter two requirements. The government acknowledged that the record did not show medical improvement allowing Ramsey to work by May 2016, that Ramsey’s IQ and consultative-examination findings remained similar, that the administrative law judge did not properly address treating-provider evidence, and that the judge relied too heavily on a one-time examiner and non-examining opinions. The government also conceded that the administrative law judge lacked valid evidentiary reasons for discounting Ramsey’s symptom reports, making the residual-functional-capacity finding and vocational testimony defective.

The court found the record sufficiently developed because the government identified nothing missing, did not explain what doubts about Ramsey’s disability remained, and did not identify any useful purpose for additional proceedings. The court also stated that the government’s conduct had unnecessarily delayed resolution of the case and further supported an award of benefits.

Disposition

Judge Edward M. Chen granted Ramsey’s motion for summary judgment and remanded the case to the agency for calculation and award of benefits. The court denied as moot Ramsey’s motion for default judgment, directed the clerk to enter judgment for Ramsey, and ordered the case closed.