Matos v. Commissioner of Social Security

Background

Raldiris Ferreras Matos brought this action under 42 U.S.C. § 405(g), challenging the Commissioner of Social Security’s denial of Matos’s applications for Disability Insurance Benefits and Supplemental Security Income. Matos moved for judgment on the pleadings, a request for judgment based on the existing administrative record. The Commissioner filed a cross-motion for judgment on the pleadings.

Magistrate Judge McCarthy recommended granting Matos’s motion, denying the Commissioner’s cross-motion, and remanding the case to the Social Security Administration for further proceedings. Neither party filed written objections. Because there were no objections, Judge Roman reviewed the recommendation for clear error—that is, an obvious mistake on the face of the record.

Reasons for Remand

The court adopted the magistrate judge’s analysis and conclusions in full. In evaluating disability claims, an administrative law judge must use a five-step process and must consider the combined effects of all medically determinable impairments, including impairments found to be non-severe, when assessing the claimant’s residual functional capacity.

The court found that the administrative law judge did not account for Matos’s depressive and anxiety disorders in the residual-functional-capacity analysis, even though the administrative law judge had found those disorders non-severe. As a result, the administrative law judge did not consider the combined effects of Matos’s mental and physical impairments. The court described that omission as reversible error.

The court also agreed that the vocational expert’s opinion was flawed because the hypothetical question given to the expert did not include Matos’s mental impairments and appeared to conflict with the Dictionary of Occupational Titles. In addition, the administrative law judge did not explicitly discuss treatment notes from several practitioners or otherwise address all relevant evidence. The court directed that those matters be addressed on remand.

Disposition

Judge Nelson S. Roman adopted the report and recommendation in its entirety. Matos’s motion for judgment on the pleadings was granted to the extent of remanding the case to the Social Security Administration for further proceedings consistent with the recommendation. The Commissioner’s cross-motion for judgment on the pleadings was denied. The clerk was directed to terminate both motions and the action.