Haddix v. Commissioner of Social Security, 3:15-cv-00109

Filisa D. Haddix received SSI as a child (1998–2011); upon reaching adulthood her eligibility was redetermined and benefits were terminated.
Redetermination was denied initially (Aug 30, 2011) and on reconsideration (Apr 12, 2012); ALJ held a hearing and found Haddix not disabled for the relevant period (alleged onset Oct 28, 2009 through insured date Dec 31, 2011).
Appeals Council denied review; Haddix sued in federal district court on Sept 9, 2015 and moved for summary judgment.
Magistrate Judge Aloi issued an R&R (Sept 27, 2016) recommending the Court grant Haddix’s motion, deny the Commissioner’s motion, and remand for further proceedings because substantial evidence did not support the ALJ’s denial.
The Commissioner objected only as to whether the R&R addressed current deficits in adaptive functioning; the district court reviewed that issue de novo.
The district court adopted the R&R, found the ALJ’s conclusion that Haddix lacked deficits in adaptive functioning was not supported by substantial evidence (noting low lifelong IQ scores and record evidence of deficits in academic, social, and communication skills), granted plaintiff’s summary judgment motion, denied the Commissioner’s, and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether substantial evidence supports the ALJ’s finding that Haddix lacks current deficits in adaptive functioning for disability determination	Haddix argued the record shows deficits in adaptive functioning (low IQ scores; limitations in academic, social, and communication skills) requiring a finding of disability or further evaluation	Commissioner argued the ALJ reasonably relied on plaintiff’s daily activities and other record evidence to conclude no current deficits in adaptive functioning	Court held the ALJ’s determination was not supported by substantial evidence; remand ordered for further consideration
Whether the Magistrate Judge’s R&R adequately considered adaptive functioning	Relying on the record and R&R, Haddix contended the R&R properly identified evidence of adaptive deficits	Commissioner objected that the R&R failed to address current adaptive functioning deficits	Court overruled the Commissioner’s objection, agreed the R&R considered adaptive functioning and found remand warranted

Richardson v. Perales, 402 U.S. 389 (1971) (standard that review is limited to whether decision is supported by substantial evidence)
Hays v. Sullivan, 907 F.2d 1453 (4th Cir. 1990) (court must determine whether Commissioner applied correct legal standards)
King v. Califano, 599 F.2d 597 (4th Cir. 1979) (reviewing court does not make factual findings or try the case de novo in disability review)
Seacrist v. Weinberger, 538 F.2d 1054 (4th Cir. 1976) (responsibility to reconcile medical evidence lies with the Commissioner, not the courts)
Webb v. Califano, 468 F. Supp. 825 (E.D. Cal. 1979) (failure to object to an R&R permits the district court to apply an appropriate standard of review)