New York Social Security Disability Lawyer Blog

In order to be eligible for Social Security disability benefits, a claimant must generally prove that he or she either hasn't worked or it is foreseeable that he or she will be unable to work of one year or more due to physical or mental impairment. The claimant's disability need not be based on one single impairment, however. Often, a claimant is rendered disabled by a combination of impairments which - individually - may or may not affect the person's ability to work. In Henderson v. Commissioner of Social Security Administration, the District Court for the Eastern District of Texas explains how the Social Security Administration (SSA), its judges and federal courts should consider a disability claim based on a combination of impairments.

Plaintiff Donna Henderson filed a Social Security disability benefits claim, alleging that she was unable to work due to degenerative disc disease, coronary disease, depression and cognitive problems resulting from a stroke. The SSA denied the claim initially and upon reconsideration. Ms. Henderson requested a hearing and, over time, went through three hearings and at least two successful appeals. After the third administrative hearing, an SSA ALJ determined that Plaintiff was not disabled for benefits purposes because, although the disc disease preventing her from performing any previous jobs, Plaintiff retained the residual functional capacity to perform a reduced range of light work, including jobs such as information clerk, "office helper" and mail room clerk.

After an unsuccessful appeal to the Appeals Council, Ms. Henderson filed suit in Federal Court where her case was turned over to a Magistrate Judge for review and recommendation. In the recommendation, the Magistrate agreed with Plaintiff that an ALJ considering a claim by a person with more than one impairment "is required to consider the combined effects of all impairments without regard to whether any such impairment, if considered separately, would be of sufficient severity." In other words, the ALJ has to look at the effect of the combined impairments, rather than the effect of each impairment individually. In so doing, the ALJ must consider the entire record, the Magistrate added. If the ALJ finds that the claimant suffers from "a medically severe combination of impairments," the ALJ must consider the combination of impairments throughout the decision process.

Notwithstanding that, the Magistrate found that the ALJ properly considered each of Plaintiff's alleged impairments and that the decision that she retained the ability to perform certain work was based on substantial evidence. As a result, the Magistrate recommended that the ALJ's decision be affirmed.