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Kreidler v. Barnhart

Citations: 385 F. Supp. 2d 1034; 2005 U.S. Dist. LEXIS 25642; 2005 WL 2086736Docket: EDCV 04-0662-RC

Court: District Court, C.D. California; July 26, 2005; Federal District Court

Narrative Opinion Summary

This case involves a plaintiff challenging the Social Security Administration's (SSA) decision to terminate her disability benefits, initially granted due to her disability status since 1991. Her benefits were terminated on October 24, 1997, following her failure to attend scheduled medical examinations required for evaluating her condition. After a telephonic hearing in 2000, a decision was made to cease her benefits due to lack of medical evidence and non-compliance. Despite a request for an administrative hearing, the plaintiff's nonappearance led to the dismissal of her request. The Appeals Council remanded the case for a new hearing, but the Administrative Law Judge (ALJ) reaffirmed the termination, citing non-cooperation. The plaintiff's appeal was denied by the Appeals Council. Under 42 U.S.C. 405(g), the court reviewed the Commissioner's decision, focusing on substantial evidence and legal standards. The ALJ found the plaintiff's failure to attend examinations constituted non-cooperation, justifying the benefits termination under 42 U.S.C. 423(f). The plaintiff's ability to attend college was noted, undermining her claims of disability. The court upheld the defendant's request, affirming the Commissioner's decision, thereby denying the plaintiff's relief.

Legal Issues Addressed

Claimant's Cooperation Requirement in Disability Determination

Application: A claimant's failure to cooperate, such as by missing medical examinations and failing to provide evidence, can justify the termination of benefits.

Reasoning: A claimant may no longer be considered disabled if their medical condition improves, allowing them to engage in substantial gainful activity, or if benefits are terminated for non-medical reasons, such as failure to cooperate in the benefit review process.

Impact of Non-Attendance at Administrative Hearings

Application: The plaintiff's nonappearance at a scheduled hearing led to the dismissal of her request for an administrative hearing, contributing to the upholding of the benefits termination.

Reasoning: Kreidler requested an administrative hearing on February 27, 2001, asserting her continued disability. However, her request was dismissed by Administrative Law Judge Alan K. Goldhammer on July 19, 2002, due to her nonappearance at the scheduled hearing...

Judicial Review of SSA Decisions under 42 U.S.C. 405(g)

Application: The court reviewed the SSA's decision to ensure that the findings were backed by substantial evidence and that proper legal standards were applied.

Reasoning: Under 42 U.S.C. 405(g), the court can review the Commissioner's decision regarding disability benefits to ensure that the findings are backed by substantial evidence and that proper legal standards were applied.

Termination of Disability Benefits under 42 U.S.C. 423(f)

Application: The plaintiff's benefits were terminated due to non-cooperation with the benefit review process, specifically her failure to attend scheduled consultative examinations and provide requested medical documentation.

Reasoning: The ALJ concluded that the plaintiff’s disability ceased for non-medical reasons due to non-cooperation, specifically citing the plaintiff's failure to attend scheduled consultative examinations and provide requested medical documentation.