Jonathan A. Z. v. Kijakazi

Background

Jonathan A. Z. sought judicial review of an administrative law judge’s decision denying his applications for benefits under Titles II and XVI of the Social Security Act. The administrative law judge found that he was not disabled from the alleged onset date of September 14, 2014, through October 1, 2019. The Appeals Council declined to review that decision. Both sides then filed motions for summary judgment, which ask the court to decide the case based on the administrative record and applicable law.

The administrative law judge found severe impairments involving Jonathan A. Z.’s right shoulder, left knee, major depressive disorder, and social anxiety. The judge concluded that he could perform light work with limitations and could perform jobs such as sorter, assembler, and inspector. Jonathan A. Z. challenged, among other things, the administrative law judge’s assessment of his residual functional capacity and the finding at the final step of the disability analysis.

Court’s analysis

The court focused on the handling of Jonathan A. Z.’s gastrointestinal conditions: irritable bowel syndrome, gastroesophageal reflux disease, and Barrett’s esophagus. The court found that the administrative law judge incorrectly treated irritable bowel syndrome as Crohn’s disease, incorrectly stated that irritable bowel syndrome was not reflected in the record, and incorrectly stated that the condition did not satisfy the required 12-month duration. The record showed repeated irritable bowel syndrome diagnoses beginning in 2016 and continuing afterward.

The court also found that the administrative law judge did not mention gastroesophageal reflux disease or Barrett’s esophagus at the second step of the disability analysis or later. Jonathan A. Z. had testified about chronic diarrhea, upper gastrointestinal distress, nausea, difficulty eating, and the effects of these problems on his other impairments. Medical records also documented the gastrointestinal diagnoses and treatment history.

An administrative law judge has a duty to fully and fairly develop the record, meaning the judge must obtain and consider information needed to make a complete disability determination. The court concluded that the medical records and testimony triggered that duty here. The court also explained that it could address the record-development problem even though Jonathan A. Z. had not specifically raised that issue, because the court independently reviews whether the agency’s findings are supported by substantial evidence—relevant evidence that a reasonable person could accept as adequate support.

Disposition

The court granted Jonathan A. Z.’s summary judgment motion and denied the Commissioner’s summary judgment motion. It remanded the case for further proceedings and a new hearing. On remand, the administrative law judge and Jonathan A. Z.’s counsel were ordered to develop the record about the gastrointestinal conditions. The Commissioner was also ordered to consider the other issues raised in Jonathan A. Z.’s briefing and to ensure that any new administrative decision addressed those issues.

The court declined to decide Jonathan A. Z.’s remaining arguments because they could be addressed after the additional record development and because the analysis of those issues could change on remand.