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Keywords

hearingmotionsummary judgmentregulationobjectionsustainedjudicial reviewmotion for summary judgment
plaintiffmotionregulation

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Hardy v. Commissioner of Social Security, 554 F.Supp.3d 900

Facts

Lakeisha Hardy, a 35-year-old woman, applied for disability insurance benefits and supplemental security income due to various physical and mental disabilities, including diabetes, carpal tunnel syndrome, and major depressive disorder. Her applications were denied after an administrative hearing, leading her to seek judicial review. The ALJ found that Hardy had not engaged in substantial gainful activity since her alleged disability onset date and determined her residual functional capacity, ultimately concluding that she was not disabled.

Plaintiff Lakeisha Hardy, a 35-year-old woman, says that she cannot work because of a variety of physical and mental disabilities.

Issue

Did the ALJ sufficiently articulate her reasons for finding the opinions of Hardy's treating physicians unpersuasive, in accordance with the new regulations governing the evaluation of medical opinions?

The sole issue for consideration is whether the ALJ sufficiently articulated her reasons for finding 'unpersuasive' the opinions of two of the plaintiff's treating physicians.

Rule

Under the new regulations, ALJs are required to articulate how persuasive they find all medical opinions in a claimant's case record, specifically addressing the supportability and consistency of those opinions.

The new (post-March 27, 2017) regulations displaced the former treating physician rule, which required substantial deference to the opinions of medical sources that had established a treating relationship with the claimant.

Analysis

The court determined that the ALJ failed to adequately explain her reasoning for rejecting the opinions of Hardy's treating physicians, as she did not discuss the supportability and consistency factors required by the new regulations. The ALJ's brief and limited explanations did not provide sufficient rationale for her decision, which frustrated the court's ability to determine whether the disability determination was supported by substantial evidence.

The court's obligation to review the ALJ's decision includes 'whether the ALJ applied the correct legal standards and whether the findings of the ALJ are supported by substantial evidence.'

Conclusion

The court rejected the magistrate judge's report and recommendation, sustained Hardy's objection, granted her motion for summary judgment in part, denied the government's motion, and remanded the case for further consideration.

Accordingly, it is ORDERED that the magistrate judge's report and recommendation (ECF No. 20) is REJECTED.

Who won?

Lakeisha Hardy prevailed in the case because the court found that the ALJ's rejection of her treating physicians' opinions was not supported by substantial evidence, necessitating a remand for proper consideration.

Claimant's motion granted in part, government's motion denied, and case remanded.

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