The U.S. District Court recently vacated and remanded a decision by the commissioner of Social Security, emphasizing the critical importance of considering all relevant medical evidence, particularly reports generated within the context of a workers' compensation claim.
Jon L. Gelman
The case, A.D. v. Commissioner of Social Security, highlights the court's analysis regarding an administrative law judge's failure to account for medical opinions from treating and examining physicians that were part of the claimant's workers' compensation file.
Court's analysis on overlooked evidence
The court found that the ALJ erred by not considering or even mentioning relevant medical evidence from several doctors, including those whose reports stemmed from the plaintiff's disputed workers' compensation claim. The commissioner argued that some of these reports were irrelevant because they were generated after the date the plaintiff was last insured or were not "treatment evidence" but opinions for workers' compensation purposes.
Impact on the decision
The ALJ's failure to consider the medical reports from the workers' compensation claim directly impacted the court's decision. The court found that the ALJ's determination of the plaintiff's residual functional capacity did not comport with the law because not all evidence was considered. This oversight constituted reversible error, leading the court to vacate the commissioner's decision and remand the case for further proceedings where the ALJ must properly consider all relevant medical evidence.
Key takeaways
Claimants' attorney Jon L. Gelman is the author of "New Jersey Workers’ Compensation Law" and co-author of the national treatise "Modern Workers’ Compensation Law." He is based in Wayne, New Jersey. This blog post is republished with permission.
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