Jamison v. Commissioner of Social Security

Background

Lisa Jane Jamison sued under 42 U.S.C. § 405(g), which allows judicial review of a Social Security decision, after the agency denied her application for Supplemental Security Income benefits. Jamison moved for an order reversing the administrative law judge’s decision. The Commissioner of Social Security cross-moved for judgment on the pleadings, asking the court to uphold the decision based on the administrative record.

The case was referred to Magistrate Judge Andrew E. Krause. He recommended granting Jamison’s motion, denying the Commissioner’s cross-motion, reversing the administrative law judge’s determination, and remanding the matter to the Social Security Administration for further proceedings under sentence four of 42 U.S.C. § 405(g). Neither party objected to the recommendation.

Court’s analysis

Because there were no objections, the district court reviewed the magistrate judge’s report for clear error on the face of the record. Judge Roman found no clear error and adopted the report and recommendation in its entirety.

The court agreed that the administrative law judge had not properly applied the Social Security Administration’s current regulations for evaluating medical opinions. Under those regulations, an administrative law judge must consider all medical opinions and assess their support, consistency with the record, treatment relationship, specialization, and other relevant factors. The administrative law judge was not required to give a treating physician’s opinion controlling weight, but still had to evaluate the opinions under the governing standards.

The court specifically found that the record lacked substantial evidence supporting the finding that Jamison could occasionally perform overhead reaching. Because the administrative law judge had applied the wrong standard and the residual-functional-capacity finding was inadequately supported, the court determined that reversal and remand were warranted.

Disposition

Judge Roman adopted the report and recommendation, granted Jamison’s motion seeking reversal of the administrative law judge’s determination, and denied the Commissioner’s cross-motion for judgment on the pleadings. The Clerk of Court was directed to enter judgment in Jamison’s favor and remand the matter to the Social Security Administration for further proceedings consistent with the report and the order. The order did not itself award benefits.