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6th Cir: SSA Reconsider Disability Benefits for Bipolar Disorder

By Robyn Hagan Cain | Last updated on

Charles Gayheart applied for Social Security disability insurance benefits (DIB) in December 2005 due to manifestations of anxiety, panic disorder, bipolar disorder, and depression. After an initial denial of his application and three separate hearings, an administrative law judge (ALJ) found that the limitations caused by Gayheart's impairments did not preclude him from working and denied his DIB application. Gayheart later lost his administrative and district court appeals.

Tuesday, the Sixth Circuit kicked Gayheart's case back to the Social Security Administration for further review.

After working as an assistant manager in an auto parts store for more than 20 years, Gayheart quit in September 2005 because he was suffering daily panic attacks in the workplace that lasted up to 15 minutes at a time. He had been taking prescription medication to treat depression, anxiety, and panic attacks since 2000. Sweating, shaking, dizziness, shortness of breath, and an accelerated heart rate accompanied the panic attacks.

After quitting his job, Gayheart sought treatment from three different mental health professionals. Multiple treating specialists diagnosed him with bipolar disorder, panic disorder, anxiety, and depression. Three doctors from the SSA's Bureau of Disability Determination found that Gayheart had problems, but he could still hold a job. Gayheart's DIB requests were denied.

The Commissioner's regulations provide a five-step process for the evaluation of disabilities. The Sixth Circuit summarized the five steps in Walters v. Comm'r of Soc. Sec as follows:

  1. If claimant is doing substantial gainful activity, he is not disabled.
  2. If claimant is not doing substantial gainful activity, his impairment must be severe before he can be found to be disabled.
  3. If claimant is not doing substantial gainful activity and is suffering from a severe impairment that has lasted -- or is expected to last -- for a continuous period of at 12 twelve months, and his impairment meets or equals a listed impairment, claimant is presumed disabled without further inquiry.
  4. If claimant's impairment does not prevent him from doing his past relevant work, he is not disabled.
  5. Even if claimant's impairment does prevent him from doing his past relevant work, he is not disabled if other work exists in the national economy that accommodates his residual functional capacity and vocational factors.

Here, the case turned on whether the ALJ appropriately deferred to the opinions of two agency doctors over the opinion of Gayheart's treating doctor in determining at step three that the combination of Gayheart's impairments didn't satisfy the impairment criteria listed and in determining the limitations on Gayheart's residual functioning capacity (RFC) for use in steps four and five.

The appellate court reasoned that "a proper analysis of the record might not support giving controlling weight to the opinions of [the treating physician]. But this circuit 'has made clear that it does not hesitate to remand when the Commissioner has not provided good reasons for the weight given to a treating physician's opinion.'"

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