Balz v. Saul

Background

Gregory Balz challenged an administrative law judge’s denial of his application for a period of disability and disability insurance benefits under the Social Security Act. The court had referred the case to Magistrate Judge Paul E. Davison, who recommended granting Balz’s motion for judgment on the pleadings, denying the Commissioner’s cross-motion, and remanding the case for further administrative proceedings. The Commissioner objected to that recommendation.

The administrative law judge found that Balz had several severe impairments, including sarcoidosis with liver calcifications, asthma, a brain aneurysm, obstructive sleep apnea, knee and spine conditions, and related nerve-root problems. The judge found that Balz had the residual functional capacity—the ability to perform work despite his limitations—to perform sedentary work with restrictions. The judge also found that Balz could not perform his past relevant work but could perform other jobs existing in significant numbers in the national economy.

Court’s analysis

The court overruled the Commissioner’s objections and agreed with Judge Davison’s recommendation. It held that the administrative law judge did not properly explain the evaluation of medical opinions under the regulations governing claims filed after March 27, 2017. Those regulations require the administrative law judge to explain how the opinions were evaluated for supportability and consistency, while also considering other relevant factors when required.

The court found that the administrative law judge’s explanation for rejecting Dr. Kevin Weiner’s opinion was too cursory. Dr. Weiner concluded that Balz was unable to work, including at the sedentary level. The administrative law judge instead found opinions from Dr. Justin Porto persuasive and Dr. A. Auerbach’s opinion persuasive, but did not adequately explain the treatment of the medical evidence or Dr. Weiner’s relationship with Balz. The court acknowledged that Judge Davison had misstated when Dr. Weiner began treating Balz, but concluded that the error did not change the analysis because Dr. Weiner had examined Balz extensively for more than one year and approximately 12 visits.

The court also held that substantial evidence did not support the assigned residual functional capacity. Dr. Auerbach found that Balz could perform light work, Dr. Porto did not give an opinion about Balz’s residual functional capacity, and Dr. Weiner found Balz unable to perform even sedentary work. The court concluded that the administrative law judge effectively selected a capacity between those opinions without affirmative medical evidence supporting that specific finding. The court further held that Dr. Porto’s statement that Balz should avoid respiratory irritants could not be treated as evidence that Balz had no other functional limitations, and that the administrative law judge could not translate raw medical findings into detailed work restrictions without adequate medical support.

Disposition

Judge Kenneth M. Karas adopted Judge Davison’s Report and Recommendation, denied the Commissioner’s motion for judgment on the pleadings, and granted Balz’s motion for judgment on the pleadings. The court reversed the Commissioner’s final decision and remanded the matter for further administrative proceedings. The clerk was directed to terminate the pending motions and close the case. The order did not itself award benefits.