Stephanie S. v. Kijakazi

Background

The parties filed cross-motions for summary judgment, asking the court to rule based on the administrative record. The court held a hearing on November 16, 2021, and ruled from the bench.

Court’s analysis

The court reviewed whether the administrative law judge’s decision was supported by substantial evidence—the level of evidentiary support required when a court reviews an administrative decision. The court focused on the administrative law judge’s treatment of the opinion of agency expert Dr. Karen Butler, who testified twice regarding Stephanie S. Dr. Butler concluded that Stephanie S. met Listing 12.04 because she had marked limitations in two areas identified in the listing’s part-B analysis. The order also stated that Dr. Benet specifically concluded that Stephanie S. met the listings beginning in October 2016.

The court held that the administrative law judge’s conclusion that Dr. Butler’s opinion was inconsistent with the overall treatment records and other evidence was itself unsupported by substantial evidence. Because that error independently required a remand, the court did not reach the parties’ two other arguments.

Ruling

The court denied the Commissioner’s motion for summary judgment, granted Stephanie S.’s motion for summary judgment, and remanded the matter to the Social Security Administration for further proceedings consistent with the order and the court’s hearing ruling. A footnote states that Stephanie S.’s counsel conceded that the claimant had not met the burden for the period from November 4, 2014, through October 2016; therefore, the remand need address only the period beginning in October 2016.