Disability Claim Remanded, Mental Health Evaluations Need More Weight

The Seventh Circuit reviewed an Administrative Law Judge's denial of an applicant's request for Supplemental Security Income ("SSI") due to physical and mental impairments. On appeal, the Seventh Circuit reversed and remanded on the issue of the determination and effect of her mental impairments.

Background

Carol Bates was in a car accident in 2004, and from that time she suffered from radiating neck pain. In the years after the accident, she had to care for her six adopted children alone, while withstanding the losses of her fiancé and mother. In 2007, Bates filed an application for SSI. In her initial application, she only mentioned the physical pain she experienced, which according to her, impaired her ability to work in, and out of, the home. She began going to therapy in 2006, and saw a psychiatrist in 2009, who diagnosed her with Bipolar Type 2 disorder.

Bates' initial SSI application was denied, and she appeal before an Administrative Law Judge ("ALJ"), who denied her application. The district court affirmed, and her appeal to the Seventh Circuit followed.

Legal Analysis

The court noted that an ALJ's credibility findings are accorded deference and are only overturned when "patently wrong." Here, the Seventh Circuit found that the ALJ did not give enough weight to the findings of Bates' psychiatrist, and to Bates' own testimony about the limitations caused by her mental illness. The court held that where the claimant's testimony matches the findings of her doctors, that evidence "should form the basis for the ALJ's determination."

Repercussions

While there is no hard and fast rule here, the Seventh Circuit clarified the appropriate weight it should give to claimant and doctor testimony in SSI application hearings. Here, the ALJ found that there may have been insufficient information, the Seventh Circuit advised that "it was [the ALJ's] responsibility to recognize the need for additional evaluations."

Related Resources:

• You Can't Perform Essential Job Duties if You Aren't There (FindLaw's U.S. Seventh Circuit Blog)
• Denial of Veteran's Claim for Disability Benefits for Diabetes Vacated (FindLaw's U.S. Seventh Circuit Blog)
• Employers Must Appoint Disabled Employees to Vacant Positions (FindLaw's U.S. Seventh Circuit Blog)