Deloatch v. Commissioner of Social Security

Background

Rebecca Deloatch sought judicial review under 42 U.S.C. § 405(g) of the Social Security Administration’s final decision denying her applications for Disability Insurance Benefits and Supplemental Security Income. She applied for both benefits in September 2016, alleging that her disability began in July 2016. After a hearing, an administrative law judge found in April 2019 that she was not disabled, and the Appeals Council declined review in June 2020.

The administrative law judge found that Deloatch had several severe physical and mental impairments, including anxiety disorder, major depressive disorder, bipolar disorder, posttraumatic stress disorder, mild neurocognitive disorder, spinal conditions, chronic pain syndrome, neuropathy, and fibromyalgia. The judge determined that Deloatch could perform a restricted range of sedentary work, including certain unskilled jobs identified by a vocational expert, and therefore was not disabled.

Parties’ Arguments

Deloatch and the Commissioner each moved for judgment on the pleadings, meaning a decision based on the pleadings and the administrative record. Deloatch argued that the administrative law judge’s residual functional capacity finding was unsupported because the judge failed to evaluate the opinion of treating physician James Gurniak and improperly evaluated opinions from treating physician Alain Mass and treating therapist Joseph Hazucha.

Court’s Analysis

The court applied the substantial-evidence standard, under which it reviews whether the Commissioner’s decision was supported by sufficient evidence and used the correct legal standard. Because Deloatch’s applications were filed before March 27, 2017, the court applied the treating-physician rule. Under that rule, an administrative law judge generally must give a treating source’s opinion controlling weight when it is well supported and consistent with the record. If the opinion is not given controlling weight, the judge must consider specified factors and provide good reasons for the weight assigned.

The court held that the administrative law judge’s decision did not mention Dr. Gurniak’s opinion. The record showed that Gurniak had treated Deloatch for two years and contained more than one hundred pages of his treatment records. Because the administrative law judge did not discuss the opinion, the judge necessarily failed to apply the required factors or provide reasons for the weight assigned to it.

The court rejected the Commissioner’s argument that the decision should be upheld because the administrative law judge properly evaluated Dr. Mass’s similar opinion. The court explained that considering Gurniak’s opinion could have changed the evaluation of the medical evidence, and the two physicians did not reach identical conclusions about Deloatch’s functional limitations.

The court did not decide Deloatch’s separate challenge to the evaluation of Dr. Mass’s opinion or Hazucha’s opinion. The court stated that its assessment of Gurniak’s opinion could affect how those other opinions are evaluated.

Disposition

The court granted Deloatch’s motion for judgment on the pleadings and denied the Commissioner’s cross-motion. It remanded the matter to the agency for further proceedings. On remand, the agency must determine the proper weight to give Dr. Gurniak’s opinion and reevaluate the evidence based on that determination. The opinion does not decide whether Deloatch is ultimately entitled to benefits.