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testimonyadministrative law
testimonyadministrative law

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Moore v. Commissioner of Social Sec. Admin., 278 F.3d 920, 78 Soc.Sec.Rep.Serv. 175, 02 Cal. Daily Op. Serv. 633, 2002 Daily Journal D.A.R. 873

Facts

James Moore, born on December 28, 1957, experienced severe depression and psychotic features following the deaths of his parents. He applied for disability benefits after his mother's death in 1989, claiming he was unable to work due to his mental health issues. Although he began working in 1991, he amended his application to request benefits only for the closed period before his employment. Multiple mental health specialists diagnosed him with significant impairments that affected his ability to work.

James Moore was born on December 28, 1957. He attended programs for developmentally delayed students in grade and high school and lived a sheltered life with his parents until he was 31 years old.

Issue

What weight may an administrative law judge give to an applicant's employment that begins after the end of the period for which the applicant is seeking Social Security disability benefits?

We are asked to decide what weight an administrative law judge may give to an applicant's employment that begins after the end of the period for which the applicant is seeking Social Security disability benefits.

Rule

An applicant's employment that begins after the end of the period for which the applicant is seeking disability benefits, unless wholly inconsistent with the claimed disability, is not a 'specific and legitimate' reason for rejecting the opinions of examining physicians.

It follows that such a record of work does not supply the more demanding 'clear and convincing' reason required to reject the medically supported testimony of an applicant.

Analysis

The court found that the ALJ improperly rejected the opinions of Moore's examining physicians based on his post-disability employment. The court emphasized that such employment does not provide a clear and convincing reason to dismiss the medically supported testimony of the claimant. The evidence indicated that Moore was disabled during the closed period and that his later ability to work did not negate his earlier claims of disability.

Moore's entry into the workforce was not wholly inconsistent with his claimed period of disability.

Conclusion

The court reversed the ALJ's finding that Moore was not disabled from April 19, 1989, to August 21, 1991, and remanded for payment of benefits for that closed period.

We reverse the ALJ's finding that Moore was not disabled from April 19, 1989 to August 21, 1991.

Who won?

James Moore prevailed in part because the court found that the ALJ had not provided sufficient legal reasons to reject the testimony of Moore and his examining physicians regarding his disability during the closed period.

The ALJ's rejection of Moore's application for disability benefits for the period between his mother's death in 1989 and his beginning of work in 1991 was not free of legal error and was not supported by substantial evidence.

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