Daniel M. v. Saul

Background

Daniel M. and the Commissioner each moved for summary judgment in this Social Security case. The court heard oral argument on May 28, 2019, ruled from the bench, and issued this order to briefly restate its decision.

The court reviewed the administrative law judge’s decision under 42 U.S.C. § 405(g). Under that standard, the court must uphold factual findings supported by substantial evidence—relevant evidence that a reasonable person would accept as adequate—but may remand when the administrative law judge has not adequately supported the decision.

Court’s Analysis

Daniel M. argued that the administrative law judge erred by failing to analyze whether his cane was medically necessary. The court agreed. Although the administrative law judge mentioned Daniel M.’s cane in passing, the judge did not determine whether it was necessary or include any cane-related limitation in the residual functional capacity assessment, which describes the work a person can still perform despite limitations.

The court relied on records from at least two providers—primary care provider Dr. Knaak and physical therapist Brian Tolley—documenting Daniel M.’s use of a walking stick or cane to help him walk. The administrative law judge also did not discuss the cane when evaluating Daniel M.’s subjective complaints. The court found the error material because the vocational expert testified that no jobs would be available under the assessed residual functional capacity if Daniel M. needed to use a cane.

Daniel M. separately argued that the administrative law judge should have given controlling weight to Dr. Knaak’s opinion. The court did not decide that issue, explaining that it would necessarily be addressed by the administrative law judge handling the case on remand.

Disposition

The court GRANTED Plaintiff’s Motion for Summary Judgment and DENIED Defendant’s Motion for Summary Judgment. It remanded the matter to the Appeals Council for further proceedings under sentence four of 42 U.S.C. § 405(g).