Scott v. Barnhart

No. 01-3302 (7th Cir. July 22, 2002) ; Clearinghouse Number: 54833

Description

ALJ Failed to Articulate Adequately Reasons for Denying Child SSI Benefits, Necessitating Remand

Abstract

The Seventh Circuit has held that the administrative law judge (ALJ) failed to articulate adequately the bases for his decision to deny plaintiff supplemental security income (SSI) childhood benefits. Plaintiff, a 12-year-old child, applied for SSI in 1994. His application was denied initially and on reconsideration, and he appealed. The ALJ concluded that plaintiff was not disabled within the meaning of the Social Security Act. The district court affirmed, and plaintiff appealed. The court of appeals held that the ALJ failed to articulate adequately the bases for his conclusions. In particular, the court found that the ALJ failed to discuss the evidence in light of Listing 112.05’s analytical framework, leaving the court with grave reservations as to whether his factual assessment addressed adequately the criteria of the listing. Furthermore, the court found that the ALJ’s failure to discuss Listing 112.05 was compounded by the ALJ’s perfunctory consideration and analysis of the evidentiary record. Plaintiff had presented medical reports from two different groups of psychologists indicating that he suffers from Developmental Expressive and Receptive Language Disorder and that he operates at the upper end of the mildly retarded range of intellectual functioning. Plaintiff had also presented a report from a third group of physicians concluding that he suffers from hyperactivity. The court noted that, rather than providing a meaningful discussion of these opinions and attempting to resolve the conflict, if any, among these different diagnoses, the ALJ merely cited the exhibit numbers and concluded that plaintiff has impairments of hyperactivity with some language, speech, and cognitive delays. Accordingly, the court reversed the judgment of the district court and remanded to the agency for further proceedings.

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Docket Date
2002-07-22 00:00:00+00:00

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