We know that the Social Security Disability claims process can be a long, complicated and even intimidating experience for a person who is injured, unable to work and seeking benefits. As the Sixth Circuit Court of Appeals' decision in Rife v. Commissioner shows, a claimant should not give up until the process is complete. We advise our clients that the initial and reconsideration denials are designed to discourage claimants from going further with their claims.
Plaintiff Donald Rife filed a claim for Social Security Disability benefits, asserting that he was unable to work due to a back injury that he sustained working on a construction job. After the Social Security Administration (SSA) denied the claim, Rife appealed and requested a hearing before an SSA Administrative Law Judge (ALJ).
The ALJ determined that Rife could not return to construction work, but was not disabled for benefits purposes because, because he retained the residual functional capacity (RFC) to perform other jobs available in the national economy.
The Appeals Council upheld the ALJ's decision and he then filed this lawsuit in federal district court. The court again affirmed the ALJ's decision, denying Rife's claim.
On further appeal, the Sixth Circuit vacated the District Court's decision and remanded the case back to the ALJ for further proceedings. The Court found that the ALJ did not provide sufficient reasoning for rejecting the opinion of plaintiff's treating physician, Dr. Hall.
As readers of this blog may know, it is well established that "the ALJ must give controlling weight to a treating source's opinion if that opinion is well-supported by medically acceptable clinical and laboratory diagnostic techniques and is not inconsistent with the other substantial evidence in your case record." If an ALJ declines to give the opinion such weight, he must provide clear reasons for discounting or rejecting the opinion, based on evidence in the record.
In this case, the ALJ dedicated only one sentence to Dr. Hall in reaching the decision, concluding that "the restrictions identified by Dr. Hall (the treating family physician) are not supported by objective evidence." The Circuit Court ruled, this was not a sufficient explanation for rejecting the doctor's opinion. "Without any indication of what weight, if any, the ALJ ascribed to Dr. Hall's opinion or the reasons for disregarding Dr. Hall's restrictions, we are unable to conduct a meaningful review of the ALJ's application of the treating-physician rule," the Court ruled.
As a result, the Court remanded the case back to the ALJ for further consideration and proceedings.
This case sends an important message to people seeking Social Security Disability benefits: Don't give up! The Circuit Court is the second highest Federal Court, below on the United States Supreme Court!
The SSA initially denies the majority of claims that are filed. We strongly believe that an initial denial is designed to discourage claimants from continuing to pursue their claims. While the ALJ hearing is often the best shot to prove a claim, sometimes the ALJ incorrectly decides a case..
An experienced Social Security Disability lawyer can represent a client throughout the disability claims process, from application to award, including in an administrative hearing before an ALJ and on to a Federal Courtl appeal if necessary. Disability attorneys who have received advocacy training are much more likely to persuade judges who might be on the fence over how to interpret certain evidence in the record.
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