SAN FRANCISCO – The U.S. District Court for the Northern District of California issued a ruling to reverse the denial of a woman’s disability benefits claim.
U.S. Magistrate Judge Maria-Elena James wrote the order for the Northern California District Court on May 2.
According to the order, Julie Dodghson filed for disability insurance benefits in 2013. Dodghson’s primary doctor, Dr. Michael Ciranni, filled out the forms as her treating physician. Her application was denied by defendant Nancy Berryhill, acting commissioner of Social Security, and she sought a hearing to appeal.
After the hearing in 2015, the administrative law judge denied her claim and ruled she was not disabled. The appeals council denied a review in March 2017, and Dodghson filed a suit requesting summary judgment.
During the process, the administrative law judge determined Dodghson had bipolar disorder, major depressive disorder, post-traumatic stress disorder, attention deficit hyperactivity disorder, and left carpal tunnel syndrome, the order states.
The administrative law judge denied Dodghson’s claim for several reasons, noting she did not find Dodghson’s testimony credible and that Ciranni’s “inconsistent” notes didn’t show the level of impairment indicated in the claim.
The appeals council said letters from Ciranni and a mental health facility staff member who treated Dodghson - who wrote letters on Dodghson’s behalf to state that she had trouble finding and maintaining employment due to lack of focus, inattention, social anxiety, sleep problems, short-term memory loss and severe fatigue - "did not provide a basis for changing the [AJL's] decision," the order states.
The defendant argued that those letters should not be reviewed in court, to which James wrote, “Defendant’s argument that this evidence should not be considered by this court is not well taken.”
James stated in the order that the administrative law judge erred by placing expert opinions who never treated Dodghson above her treating physician, “mischaracterized” her medical record and did not provide “clear and convincing reasons” as required for rejecting Ciranni’s opinions.
The order furthered that the administrative law judge erred by focusing solely on “isolated records” to ultimately decide that Dodghson’s mental health conditions did not impair her to work, which “ignores the nature of plaintiff’s bipolar disorder,” and that the letters from Ciranni and the other clinician “establish that the reasons offered by the (administrative law judge) for rejecting Dr. Ciranni’s testimony are not based on substantial evidence.”
James ordered summary judgment to Dodghson and remanded the case for further administrative hearings to reevaluate the treating physician’s opinions and records.
U.S. District Court for the Northern District of California case number 3:17-cv-02602-MEJ