Morales v. Berryhill
- George Daniels
- 1:19-cv-03075
- U.S. District Court · Southern District of New York
- 3
In Morales v. Berryhill, Judge Daniels granted Morales’s motion, denied the Commissioner’s cross-motion, and remanded the disability-benefits case for further proceedings.
Christopher Morales’s claim for disability insurance benefits will receive further administrative proceedings; the Commissioner’s denial was not left in place by this order.
What happened
Christopher Morales asked the court to review an administrative law judge’s decision denying him disability benefits. Both sides asked for judgment based on the written record.
A magistrate judge found several errors, including improper treatment of conflicting Global Assessment of Functioning scores, unexplained use of those scores in evaluating medical opinions, and rejection of a medical examiner’s opinion based on the administrative law judge’s own view of the evidence.
Judge Daniels adopted the magistrate judge’s recommendation, granted Morales’s motion, denied the Commissioner’s cross-motion, and remanded the matter for further proceedings.
The detailed version
- Morales v. Berryhill · No. 1:19-cv-03075
- George Daniels
- Sept. 15, 2020
Background
Christopher Morales brought this action under the Social Security Act seeking review of an administrative law judge’s decision denying his claim for disability insurance benefits. Both parties moved for judgment on the pleadings, meaning they asked the court to decide the case based on the existing record without a trial.
Magistrate Judge Sarah Netburn issued a Report and Recommendation on August 31, 2020. She recommended granting Morales’s motion, denying the Commissioner’s cross-motion, and sending the case back for further proceedings. Neither party objected to the recommendation.
Court’s Analysis
Because there were no objections, the court reviewed the Report and Recommendation for clear error. The court found no error, clear or otherwise, and agreed with Magistrate Judge Netburn’s conclusions that the administrative law judge made several errors.
The administrative law judge improperly relied on Morales’s higher Global Assessment of Functioning scores when denying his claim without discussing conflicting treatment notes or the circumstances in which the scores were assigned. The judge also discounted lower scores based on their context, used unexplained scores when evaluating the opinions of Morales’s consultative examiner and the Social Security Agency’s non-examining consultant, and improperly substituted his own judgment for that of the consultative examiner when rejecting the examiner’s opinion.
Disposition
Judge Daniels adopted the Report and Recommendation. The court granted Morales’s motion for judgment on the pleadings, denied the Commissioner’s cross-motion for judgment on the pleadings, and remanded the matter for further proceedings. The clerk was directed to close the motions.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.