Aaron H. v. Kijakazi
- Paul Magnuson
- 0:22-cv-00670
- U.S. District Court · District of Minnesota
- 7
Aaron H. v. Kijakazi: Judge Magnuson granted Aaron H.’s motion, denied the Commissioner’s motion, and remanded the Social Security case for further proceedings.
Aaron H. received a favorable ruling requiring the Commissioner to reconsider the matter in further proceedings. The order did not itself award benefits.
What happened
In Aaron H. v. Kijakazi, Aaron H. sought Supplemental Security Income based on physical and mental-health conditions. An administrative law judge decided that he was not disabled and could perform work available in the national economy.
Aaron H. argued that the judge failed to consider whether homelessness and mental-health problems affected his treatment compliance. He also argued that the judge improperly evaluated medical opinions. The government disagreed about whether the treatment-compliance rule applied.
The court found that these errors could have affected the disability decision and ordered further proceedings. Judge Magnuson granted Aaron H.’s summary-judgment motion, denied the Commissioner’s motion, and remanded the matter to the Commissioner.
The detailed version
- Aaron H. v. Kijakazi · No. 0:22-cv-00670
- Paul Magnuson
- Oct. 20, 2022
Background
Aaron H. applied for Supplemental Security Income on November 28, 2016. He alleged disability from insulin-dependent diabetes with peripheral neuropathy, plantar fasciitis, hip arthritis, a fractured elbow, post-traumatic stress disorder, major depressive disorder, obesity, sleep apnea, hypertension, and alcohol use disorder. He later amended his alleged disability-onset date to June 1, 2019.
Aaron H. had two hearings before an administrative law judge. Both resulted in findings that he was not disabled, but the Appeals Council reversed the first decision because the evidence did not support the findings about his limitations and because the administrative law judge had not properly applied his activity restrictions to job duties. The decision challenged in this case was issued after that remand.
Issues
The administrative law judge found that Aaron H. had several severe impairments but that none, alone or in combination, met or medically equaled a listed impairment. The judge also found that Aaron H. retained the capacity to perform work existing in substantial numbers in the national economy.
Aaron H. challenged the judge’s treatment of his alleged failure to comply with medical treatment. He argued that the judge needed to consider whether his mental-health conditions and economic circumstances, including periods of homelessness, explained that noncompliance. The government argued that the good-cause standard in Social Security Ruling 18-3p did not apply because the administrative law judge had not found Aaron H. disabled.
The court concluded that the administrative law judge’s decision repeatedly relied on treatment noncompliance, but did not consider whether homelessness or mental-health problems contributed to it. The court also found that the judge repeatedly noted that Aaron H. drove without a license, even though the court said that fact was not relevant to the disability inquiry.
The court further identified possible errors in evaluating medical opinions. The administrative law judge discounted several 2017 opinions as too distant from the alleged onset of disability, while crediting another opinion from the same period without addressing the apparent inconsistency. The judge also essentially disregarded an opinion from Aaron H.’s longest-term medical and mental-health provider without apparently considering the length of the treatment relationship or the provider’s specialized training, as required by the regulations applicable to the application.
Ruling
The court reviewed the decision to determine whether it was supported by substantial evidence in the record and complied with applicable legal standards. It held that the administrative law judge’s failure to consider factors that could explain treatment noncompliance, together with the apparent errors in evaluating medical opinions, could not be treated as harmless.
The court therefore ordered:
- Aaron H.’s motion for summary judgment was granted.
- The Commissioner’s motion for summary judgment was denied.
- The matter was remanded to the Commissioner pursuant to sentence four of 42 U.S.C. § 405(g) for further proceedings.
Judge Paul A. Magnuson did not award benefits in this order; he sent the matter back to the Commissioner for additional proceedings.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.