Circuit reverses ALJ on social security benefits

The Court of Appeals has reversed the findings of the Social Security Administration and found that a woman is entitled to Supplemental Security Income because she is in fact disabled and cannot work a full range of jobs.

The case is Rucker v. Kijakazi, issued on September 6. People who apply for SSI benefits have to proceed to a hearing, where an administrative law judge hears medical evidence from both sides before determining whether the applicant can recover these benefits because of their inability to work as a result of their disability. Courts will defer to the ALJ's findings, a process consistent with the general rule that courts give these experts the benefit of their experience; the applicants for these benefits prevail on appeal only when the ALJ blows it.

As the Second Circuit (Leval and Parker) sees it, the ALJ got it wrong in finding that Rucker can perform the full range of work at all exertional levels and has the basic capacity to read spell or perform mathematical functions. The ALJ did say Rucker cannot work with others and should avoid work that involves joint effort. In fact, the Court of Appeals says, the medical evidence shows that plaintiff is moderately limited in her ability to accept instructions, respond appropriately to criticism from supervisors, get along with coworkers and peers, and suffers from borderline personality disorder and schizoaffective disorder. Rucker gets her benefits and the ALJ's findings on this point are overturned.

The Court does uphold the ALJ's findings that Rucker's physical impairments do not render her physically disabled. The test is whether she had a severe impairment that could be expected to result in death or that could last for a continuous period of 12 months. While Rucker is obese, there is no evidence that that condition imposes any limitations on her functional capacity. 

Judge Menashi dissents from the first holding, stating that the "substantial evidence" standard applicable in administrative law cases like this supports the ALJ's findings. He writes that while the ALJ limited the amount of time Rucker should spend with coworkers, the ALJ also said Rucker can work alone and can perform simple tasks and follow simple instructions.