Williams v. Commissioner of Social Security

Background

Janice Williams sought judicial review of the Social Security Administration’s denial of her applications for Supplemental Security Income and disability insurance benefits. She alleged that a 2015 workplace back injury, obesity, and depression prevented her from working beginning October 16, 2016.

After a hearing, Administrative Law Judge Denise M. Martin found that Williams had severe lumbar facet arthropathy with lumbar straightening, obesity, and major depressive disorder. The administrative law judge decided that Williams could perform a reduced range of light work, with restrictions including a sit-and-stand option, limits on climbing and certain physical activities, avoidance of dangerous conditions, and simple, routine, non-fast-paced tasks. The judge found that Williams could not perform her past work but could perform other jobs identified by a vocational expert, including small-parts assembler, inspector or hand packager, laundry folder, document preparer, check weigher, and final assembler.

The Social Security Administration’s Appeals Council denied review, making the administrative law judge’s decision the agency’s final decision. In the federal case, the Commissioner moved for judgment on the pleadings, asking the court to uphold the administrative decision. Williams cross-moved to remand the case so the agency could consider additional medical evidence.

New Medical Evidence

After the administrative hearing, Williams obtained examinations and imaging of her cervical spine and thoracic spine. The evidence included an August 2021 cervical-spine magnetic resonance imaging scan showing moderate spinal canal narrowing, degenerative changes, and pressure on the spinal cord; a thoracic-spine magnetic resonance imaging scan showing narrowing and flattening near the spinal cord; and a September 2021 computed tomography scan showing spinal canal narrowing with myelopathy, meaning spinal-cord injury associated with compression.

The court found that this evidence was new and not merely repetitive of the existing record. Before the administrative hearing, the available spinal evidence primarily concerned Williams’s lower back because her workers’ compensation coverage did not cover testing or treatment for her neck and upper back. The court also found good cause for Williams’s failure to submit the evidence earlier because the testing was not previously available to her.

The court further found the evidence material. It related to the period for which Williams sought benefits because it concerned the same spinal injury and shed light on the severity and continuity of her earlier complaints of neck and upper-back pain. The evidence was also reasonably likely to influence the disability determination because it contradicted the administrative law judge’s statements that there was no evidence of spinal-canal narrowing or compression.

Court’s Ruling

Judge Valerie Figueredo granted Williams’s motion to remand and denied the Commissioner’s motion for judgment on the pleadings. The case was remanded to the Commissioner for further proceedings consistent with the opinion, including consideration of the new cervical- and thoracic-spine evidence together with the existing administrative record.

The court stated that Williams could also present her later mental-health treatment, diagnoses, and psychiatric medication evidence at a new hearing. It did not decide whether that psychiatric evidence independently qualified as new evidence supporting remand. Because the case was being remanded, the court also did not decide whether the administrative law judge’s original determination was supported by substantial evidence. The opinion does not state that benefits were awarded.