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Kenner v. Berryhill

Citation: 316 F. Supp. 3d 530Docket: Civil Action No. 16-01589 DAR

Court: Court of Appeals for the D.C. Circuit; July 31, 2018; Federal Appellate Court

Narrative Opinion Summary

In this case, the plaintiff sought judicial review of the Social Security Administration's final decision denying her disability insurance benefits under Section 405(g) of the Social Security Act. The case was presided over by a United States Magistrate Judge who evaluated motions from both parties: the plaintiff's motion for judgment of reversal and the defendant's motion for affirmance. The plaintiff's application, filed in 2013, was denied after the ALJ determined she was not disabled during the relevant period. The ALJ ruled that despite severe impairments, the plaintiff retained the capacity for medium work. The plaintiff challenged this decision, arguing the ALJ improperly evaluated medical opinions from her treating physicians and discredited her testimony, thus lacking substantial evidence. The court found that the ALJ failed to apply the treating physician rule, as opinions from the plaintiff's doctors were not given due weight. Moreover, the court deemed the defendant's responses insufficient, particularly in addressing critical medical evidence and procedural deficiencies. Consequently, the court granted the plaintiff's motion for judgment of reversal and remanded the case for an immediate award of benefits, emphasizing that further proceedings would unnecessarily delay the plaintiff's entitlement to benefits. This decision reflects the court's application of the substantial evidence standard and the immediate award of benefits in cases where the administrative decision is not adequately supported.

Legal Issues Addressed

Evaluation of Medical Opinions under 20 C.F.R. 404.1527

Application: The ALJ failed to properly evaluate the opinions of Plaintiff's treating physicians, which is essential for determining the weight of medical evidence.

Reasoning: Plaintiff seeks to overturn the Commissioner's final decision regarding her disability benefits, arguing that the decision lacks substantial evidence. She requests either a reversal with an award of past-due benefits from her application date or a remand for a rehearing.

Immediate Award of Benefits

Application: The court exercises its discretion to order an immediate award of benefits due to the Defendant's concession and inadequacy of the ALJ's medical evidence evaluation.

Reasoning: Consequently, the court finds that an immediate award of benefits is justified, citing the improper application of the treating physician rule and the Defendant's concession regarding the inadequacy of the ALJ's evaluation of medical opinion evidence.

Judicial Review under Social Security Act Section 405(g)

Application: Plaintiff seeks judicial review of the Commissioner's decision, challenging the denial of disability benefits as lacking substantial evidence.

Reasoning: Annette M. Kenner seeks judicial review of the Social Security Administration's final decision denying her disability insurance benefits under Section 405(g) of the Social Security Act.

Substantial Evidence Standard

Application: The court determines the Commissioner's decision is unsupported by substantial evidence, leading to the case being remanded for an award of benefits.

Reasoning: Courts must be deferential to the agency's fact-finding and should not reweigh evidence or conduct a de novo review.

Treating Physician Rule

Application: The ALJ did not adequately apply the treating physician rule, failing to give controlling weight to treating physicians' opinions without substantial evidence to the contrary.

Reasoning: The ALJ failed to apply the treating physician rule, neglecting to acknowledge or adequately address the opinions of three treating physicians: Dr. Craig Geist, Dr. Miller, and Dr. Jason Wexler.