Stacey S. v. Saul
- Ann Montgomery
- 0:18-cv-03358
- U.S. District Court · District of Minnesota
- 5
In Stacey S. v. Saul, Judge Montgomery remanded the benefits dispute after finding the administrative judge had not explained a key medical finding.
Stacey S. and the Commissioner of Social Security; the Social Security Administration must conduct further proceedings on remand.
What happened
In Stacey S. v. Saul, Stacey S. challenged the denial of Social Security benefits. A magistrate judge recommended sending the case back for further proceedings because the administrative law judge did not clearly explain part of the decision.
The disputed issue was whether Stacey S.’s mild brain atrophy and encephalopathy met or equaled a listed mental impairment. The administrative law judge found moderate limitations in concentration, persistence, or pace but did not explain what evidence supported that finding or discuss several potentially important medical opinions.
Judge Ann Montgomery overruled the Commissioner’s objection, adopted the magistrate judge’s recommendation, granted in part and denied in part Stacey S.’s motion for summary judgment, denied the Commissioner’s motion for summary judgment, and remanded the matter for further proceedings.
The detailed version
- Stacey S. v. Saul · No. 0:18-cv-03358
- Ann Montgomery
- Mar. 17, 2020
Background
Stacey S. sought judicial review of the Commissioner of Social Security’s decision denying benefits. Magistrate Judge Tony N. Leung recommended that Stacey S.’s motion for summary judgment—a request for judgment based on the existing record—be granted in part and denied in part, that the Commissioner’s motion for summary judgment be denied, and that the matter be sent back to the Social Security Administration for further proceedings. The Commissioner objected to the recommendation.
Court’s Analysis
The court independently reviewed the parts of the recommendation challenged by the Commissioner. Under the Social Security review standard, the Commissioner’s decision must comply with the law and be supported by substantial evidence, meaning enough evidence that a reasonable person would consider adequate.
The recommendation concluded that the administrative law judge needed to reconsider whether Stacey S.’s record of mild brain atrophy and encephalopathy met or equaled Listing 12.02. The court agreed that the administrative law judge did not make clear what evidence supported the finding that Stacey S. had moderate, rather than extreme, limitations in concentration, persistence, or pace. The court noted that an extreme limitation in one of the required categories could satisfy the listing.
The court also agreed that the administrative law judge did not discuss several potentially decisive medical opinions. Because the administrative law judge’s explanation was inadequate, the court could not determine whether the decision was supported by substantial evidence. The court rejected the Commissioner’s attempt to justify the decision with explanations offered after the administrative law judge’s decision and concluded that the omissions could have affected the outcome.
Disposition
Judge Ann D. Montgomery overruled the Commissioner’s objection and adopted the Report and Recommendation. The court granted in part and denied in part Stacey S.’s motion for summary judgment, denied the Commissioner’s motion for summary judgment, and remanded the matter under Sentence Four of 42 U.S.C. § 405(g) for further proceedings consistent with the recommendation and the opinion.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.