Law School Case Brief
Hart v. Massanari - 192 F. Supp. 2d 31 (W.D.N.Y. 2001)
In reviewing a decision of the Commissioner of Social Security, the issue to be determined by a court is whether the commissioner's conclusions are supported by substantial evidence in the record as a whole or are based on an erroneous legal standard. It is well settled that it is not the function of a reviewing court to determine de novo whether the claimant is disabled. Assuming the commissioner has applied proper legal principles, judicial review is limited to an assessment of whether the findings of fact are supported by substantial evidence, if they are supported by such evidence, they are conclusive. Substantial evidence is defined as more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Where there are gaps in the administrative record or where the commissioner has applied an incorrect legal standard, remand for further development of the record may be appropriate. However, where the record provides persuasive proof of disability and a remand would serve no useful purpose, the court may reverse and remand for calculation and payment of benefits.
Ginger E. Hart (Ginger) was born in 1984, making her 17 years of age. Plaintiff (mother) filed a claim, alleging that her daughter is disabled and entitled to benefits under section 1602 of the Social Security Act, Supplemental Security Income for the Aged, Blind, and Disabled (codified at 42 U.S. Code § 1381a). The mother protectively filed an application for supplemental security income (SSI) on October 6, 1996. The application was denied initially and on reconsideration. The mother filed a request for a hearing before an Administrative Law Judge (ALJ) and the hearing was held on April 6, 1998. On April 20, 1998, the ALJ found Ginger was not eligible for SSI. That decision became the Commissioner's final decision when the Appeals Council denied the mother's request for review on May 19, 2000. The mother commenced a civil action.
Was the Commissioner's decision supported by substantial evidence?
After the ALJ's decision, the Commissioner clarified the definition of "extreme" as when the impairment interfered very seriously with the ability to independently initiate, sustain, or complete activities. Based upon the Commissioner's clarification, the court found that the Commissioner's decision was not supported by substantial evidence. The record, which included the daughter's history of pervasive social delays and lack of self-control, made it clear that the daughter's disability met the definition of severe limitation in the domain of social functioning.
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