A plaintiff appealed his case to United States District Court in Kansas to reverse an administrative decision denying him Social Security Disability insurance benefits. The administrative hearing was conducted in 2018 after the application was denied a year earlier. The administrative law judge determined the applicant did not qualify to receive social security disability insurance benefits. However, in December 2019, the Court upheld the administrative decision regarding the plaintiff’s request for disability benefits.
How Social Security Act Applicants Qualify for Benefits
In order to qualify for disability benefits, claimants need to have worked in jobs covered by Social Security. Under the Social Security Act (SSA), they must establish they are “disabled” during the time the claimant had “insured status” in the Social Security program. According to 42 U.S.C.A. § 423, “disabled” requires that claimants be unable to “engage in any substantial gainful activity” due to physical or mental impairment that has lasted or can last a minimum of 12 months. Impairments include standing, walking, sitting, and remembering.
People that work and earn an average of more than $1,220 a month cannot be considered disabled. Medical impairments that do not prevent claimants from performing any of their past work are disqualified from disability benefits. The burden is on the claimant to prove a disability that prevents performance of past relevant work.
Eligible Medical Conditions
The Social Security program also contains a list of lists of medical conditions it regards severe enough that it “prevents persons from completing the substantial gainful activity.” Medical conditions SSA considers severe include acute leukemia, ALS, and pancreatic cancer. The last step of the evaluation process is to determine whether there is any other type of work the applicant can work in. The applicant’s residual functional capacity, age, education and work experience are considered in this evaluation. This last step of the evaluation process has the burden-shifting to the Commissioner of the Social Security Administration to prove there are jobs available with the applicant’s residual functional capacity.
Administrative Law Judge Decision
The Administrative Law Judge (ALJ) found the plaintiff’s application should be denied based on the following information: The ALJ determined the plaintiff met the insured status requirements for Social Security benefits through the end of 2019. The ALJ found the plaintiff could perform unskilled work, limited to “routine, repetitive tasks that require no more than occasional contact with coworkers or supervisors.” The ALJ also determined that although the plaintiff cannot perform his past relevant work but could perform other jobs such as “semiconductor assembler, printed circuit board inspector, and wire wrapper.
The plaintiff has a seventh-grade level of education. His work experience was in construction and working in a warehouse. The plaintiff suffered a heart attack in 2017. He reported he was resuscitated after he had no heartbeat or breathing from eight to eleven minutes.
Plaintiff’s Physician Testimony
Dr. Quillen evaluated the plaintiff and determined he suffered from mental problems. Dr. Quillen concluded the plaintiff’s conditions would prevent him from competitive employment. He indicated the plaintiff was unable to understand, carry out and remember simple instructions, and unable to sustain concentration and working a work-related activity at a reasonable pace.
The ALJ did not regard Dr. Quillen’s opinion as persuasive. The ALJ noted evidence that showed the plaintiff’s mental and physical abilities were not impaired. For example, later examinations did not document any type of cognitive decline. The ALJ determined the plaintiff was able to engage in daily living activities, such as cooking, cleaning, driving, and personal finance. The ALJ also determined Dr. Quillen’s opinion was not consistent with his own examination findings.
U.S. District Court’s Decision
The Court found substantial evidence supporting the ALJ’s reasoning and analysis of the plaintiff’s daily activities. The Court also indicated ALJ did not discount Dr. Quillen’s report solely because of the plaintiff’s daily living activities. It evaluated the plaintiff’s disability based on medical reports of his physical conditions and that of the state psychological consultants.
The plaintiff submitted medical records indicating the plaintiff had mild bilateral carpal tunnel syndrome once the ALJ made his decision to deny benefits to the plaintiff. The Appeals Council determined the evidence did not relate to the period of disability the plaintiff alleged. The medical records were from August 2018, while the plaintiff’s case was decided through June 4, 2018. The U.S. District Court concurred with the Appeals Council decision that the evidence did not relate to the period on or before the ALJ’s decision. The court affirmed the decision to deny the plaintiff’s application for social security benefits.
If you have been denied Social Security Disability or SSI benefit claim, it is important to request an appeal as soon as possible. Applicants have 60 days after receiving notice to request an appeal. You can request an appeal online, in a hearing before an administrative law judge, or in a review by the Appeals Council. If you have questions about your Social Security disability benefits, contact the attorneys at Whitcomb Selinsky PC at (303) 534-1958.