Benefit Denial Must Be Backed by Reasons, not References
Charles Kastner sought disability insurance benefits because he was suffering from a degenerative disc disorder. He claimed that his disorder of the spine constituted a disability under the Social Security Act. An administrative law judge (ALJ) disagreed, concluding that Kastner's impairments were severe, but did not meet the requirements for a presumptively disabling condition. The ALJ concluded that Kastner had residual capability to perform certain jobs in the economy.
After losing a challenge before the district court, Kastner may have found relief in the Seventh Circuit Court of Appeals. Wednesday, the Seventh Circuit reversed the district court's judgment, concluding that the ALJ had not adequately explained why Kastner did not met the requirements for a presumptive disability.
Kastner was 48 years old at the time of the ALJ's decision and has past work experience as a truck driver. In 2004, Kastner injured himself while as a delivery manager for a hardware retailer, loading heavy pieces of equipment onto trucks for delivery to customers. That injury aggravated a 16-year-old disc injury, which eventually required surgery.
In 2006, an ALJ concluded that Kastner could perform sedentary work and denied disability benefits.
To determine whether a claimant is disabled, an ALJ employs a five-step inquiry which asks:
- Whether the claimant is currently employed.
- Whether the claimant has a severe impairment.
- Whether the claimant's impairment is one that the Social Security Commissioner considers conclusively disabling.
- If the claimant does not have a conclusively disabling impairment, whether he can perform his past relevant work.
- Whether the claimant is capable of performing any work in the national economy.
The ALJ found that Kastner had satisfied steps 1 and 2, but determined that Kastner's conditions did not meet the requirements for presumptive disability under step 3. The ALJ noted that Kastner did not display the limitation of motion anticipated by the regulation, but she didn't offer specifics as to what she meant.
Kastner challenged the ALJ's adverse determination at step 3, arguing that, under a theory of presumptive liability, a claimant is eligible for benefits if he has a condition that meets or equals an impairment found in the Listing of Impairments. Each listing has a set of criteria which must be met for an impairment to be deemed conclusively disabling. Kastner contends that his condition meets or equals the requirements for disorders of the spine in the Listing.
The Seventh Circuit Court of Appeals has repeatedly held that an ALJ must provide a logical bridge between the evidence in the record and her conclusion. Since that bridge was lacking in Kastner's case, the appellate court remanded the matter to the Social Security Administration for further proceedings.
Related Resources:
- Kastner v. Astrue (Seventh Circuit Court of Appeals)
- 6th Cir Adopts 'Harmless Error' in Disability Benefits Appeals (FindLaw's Sixth Circuit Blog)
- Employers Must Appoint Disabled Employees to Vacant Positions (FindLaw's Seventh Circuit Blog)