Lester v. Chater

93-36136 (9th Cir. Nov. 3, 1995). ; Clearinghouse Number: 51184

Description

Administrative Law Judge Fails to Consider Combined Effect of Disability Claimant’s Physical and Mental Impairments

Abstract

The Ninth Circuit has held that the Commissioner of the Social Security Administration (SSA) failed to take into account the combined effect of plaintiff’s mental and physical impairments in determining whether his condition equaled a listed impairment. After injuring his back in 1968 while working as a meat cutter, plaintiff received disability benefits from 1968 to 1974. He then worked at various part-time jobs but ceased working altogether in 1982 due to worsening back pain. When he reapplied for disability benefits in 1984, his application was denied, and he appealed. The administrative law judge (ALJ) concluded that, although plaintiff had medically determinable mental impairments (specifically, depression and a personality disorder), those impairments resulted in only "moderate" limitations on his functional capacity. The Appeals Council and the district court affirmed. The court of appeals held that the ALJ applied an incorrect legal standard in assessing whether plaintiff’s combined impairments equaled the listing for "affective disorders." Given that the consequences of plaintiff’s physical and mental impairments are inextricably linked, SSA must consider whether taken together they result in limitations equal in severity to those specified in the listings. The court also found that the ALJ erred in rejecting his treating physicians’ reports because they conflicted with the testimony of a nonexamining medical advisor and that the ALJ erred in not offering any specific reasons for her disbelief in plaintiff’s complaints of pain. The evidence, when given the effect required by law, demonstrated that plaintiff met or equaled the listing for affective disorders; thus, the court remanded for payment of benefits.

Additional Information

Docket Date
1970-01-01 06:00:00+00:00

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