Jones v. Astrue
396 U.S. App. D.C. 235
| D.C. Cir. | 2011Background
- Jones seeks SSI disability benefits for back, cardiac, pulmonary, and other impairments; prior car accident in 2006 worsened back problems; he worked manual labor and argues he cannot perform such work since 2004; SSA applied a five-step framework and the ALJ found him not disabled in 2008; the ALJ rejected treating-physician Sardana's four-hour sit limitation but did not adequately explain the rejection; district court affirmed, Jones appealed with new letters and a Superior Court transcript as potential new evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Treating physician rule violation | Jones | Astrue | Remand required for explanation of rejection of Sardana's opinion |
| Adequacy of ALJ's reasoning | Jones | Astrue | ALJ failed to provide reasons for weight given to Sardana and conflicting opinions; remand warranted |
| Sentence-four remand appropriateness | Jones | Astrue | Court should remand to articulate weight given to treating physician’s conclusions |
| Sentence-six new evidence remand | Jones/Amicus | Astrue | New Board of Medicine letter and Superior Court transcript satisfy sentence-six remand requirements |
Key Cases Cited
- Butler v. Barnhart, 353 F.3d 992 (D.C.Cir.2004) (treating physician rule requires reasons for weight given to treating source)
- Williams v. Shalala, 997 F.2d 1494 (D.C.Cir.1993) (need for reasons when rejecting treating physician's opinion)
- Simms v. Sullivan, 877 F.2d 1047 (D.C.Cir.1989) (ALJ must credit treating source with explanation for weight)
- Sullivan v. Finkelstein, 496 U.S. 617 (Supreme Court) (sentence-six remand standard for new evidence)
- Melkonyan v. Sullivan, 501 U.S. 89 (Supreme Court) (materiality and potential impact of new evidence)
- Caulder v. Bowen, 791 F.2d 872 (11th Cir.1986) (new objective evidence as basis for remand)