Jason H. v. O'Malley
- Elizabeth Cowan Wright
- 0:23-cv-00743
- U.S. District Court · District of Minnesota
- 5
In Jason H. v. O’Malley, Judge Wright adopted a recommendation, denied summary judgment, and sent the disability-benefits case back for further proceedings.
Jason H.’s disability-benefits claim was sent back to the Social Security Administration for further administrative proceedings. The Commissioner’s request to affirm the denial and motion for summary judgment were denied.
What happened
In Jason H. v. O’Malley, Jason H. asked the court to review the Social Security Administration’s denial of his disability-benefits application. The magistrate judge recommended granting his request for relief in part and denying it in part, while denying the Commissioner’s request for summary judgment.
The Commissioner objected, arguing that the administrative law judge properly addressed limits on using foot controls and that identified jobs did not require foot controls. The court rejected those arguments because the administrative law judge did not adequately explain the conflict between accepting a doctor’s opinions and leaving out part of the doctor’s limitation, and because the job descriptions did not resolve whether foot controls were required.
Judge Wilhelmina M. Wright overruled the objections and adopted the recommendation. The court granted Jason H.’s motion for relief in part and denied it in part, denied the Commissioner’s summary-judgment motion and duplicative request, and remanded the matter to the Social Security Administration for further proceedings.
The detailed version
- Jason H. v. O'Malley · No. 0:23-cv-00743
- Elizabeth Cowan Wright
- Feb. 7, 2024
Background
Jason H. sought judicial review of the Commissioner of the Social Security Administration’s decision denying his application for disability benefits. Jason H. moved for relief, and Martin J. O’Malley moved for summary judgment. United States Magistrate Judge Leo I. Brisbois recommended granting Jason H.’s motion for relief in part and denying it in part, denying O’Malley’s motion for summary judgment, and remanding the matter for further administrative proceedings. O’Malley objected to that recommendation.
The objections
O’Malley argued that the magistrate judge had not properly considered whether a limitation on “repetitive” operation of foot controls would prevent Jason H. from performing jobs involving frequent or more strenuous repetitive use of foot controls.
The court rejected that objection. It explained that the magistrate judge had considered the argument and correctly found that the administrative law judge (ALJ) had not adequately developed the record for meaningful review. The ALJ used general references to the evidence and did not sufficiently explain the apparent contradiction between finding Dr. Larbi-Odam’s opinions persuasive and not including all of the doctor’s stated limitations in the residual functional capacity determination. Because the explanation was missing, the court could not determine whether the ALJ’s decision was supported by substantial evidence.
O’Malley also argued that the ALJ’s decision should be affirmed because a vocational expert identified jobs that did not require foot controls. The court rejected that argument because the job descriptions in the Dictionary of Occupational Titles did not address whether foot controls were required or identify all of the jobs’ possible physical, mental, and environmental demands. The record also did not show that foot controls were required for those jobs.
Ruling
Judge Wilhelmina M. Wright found no clear error in the remainder of the magistrate judge’s report and recommendation and adopted it. The court overruled O’Malley’s objections; granted Jason H.’s motion for relief in part and denied it in part, as set forth in the report and recommendation; denied O’Malley’s motion for summary judgment; and denied O’Malley’s duplicative brief requesting relief by affirming the Commissioner’s decision.
The court remanded the matter to the Social Security Administration under sentence four of 42 U.S.C. § 405(g) for further administrative proceedings consistent with the order. The opinion does not state that Jason H. was awarded benefits.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.