RIVERA v. DUDEK
5:24-cv-04765
E.D. Pa.Jun 23, 2025Background
- William R. applied for Supplemental Security Income (SSI), alleging disability due to several physical and psychological impairments, notably PTSD, depression, bipolar II disorder, and physical pain conditions.
- His SSI application was denied at initial stages and by the Administrative Law Judge (ALJ) after a hearing; the Appeals Council also denied review, making the ALJ’s decision final.
- The ALJ recognized some of William’s mental impairments (PTSD, depression, anxiety) as severe but did not mention or assess his documented bipolar II disorder.
- William R. appealed to the District Court, arguing, among other things, that the ALJ's failure to address his bipolar II disorder required remand.
- The Court’s review focused on whether the ALJ failed to assess all medically documented impairments and improperly evaluated the medical evidence and RFC (residual functional capacity).
- The Court granted William's request for review and remanded the case for the ALJ to consider his bipolar II disorder at all relevant steps.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to consider bipolar II disorder | ALJ ignored key, well-documented impairment | ALJ considered all evidence; other mental impairments covered | Failure required remand for proper consideration |
| Interpretation of neuropathy | ALJ downplayed more serious nerve condition | "Peripheral neuropathy" covers his diagnosis | ALJ's terminology sufficient; no remand required |
| Consideration of 2023 spine MRI | ALJ should have addressed latest/most serious MRI | ALJ’s summary sufficient, plaintiff shows no extra limits | No remand for not mentioning every piece of evidence |
| Evaluation of other RFC/impairment issues | RFC overstated capacity, improperly limited evidence | ALJ properly formulated RFC from available evidence | Not reached (could change on remand) |
Key Cases Cited
- Burnett v. Comm’r of Soc. Sec., 220 F.3d 112 (3d Cir. 2000) (ALJs must explain reasons for rejecting evidence)
- Sykes v. Apfel, 228 F.3d 259 (3d Cir. 2000) (explains the five-step disability analysis)
- Hartranft v. Apfel, 181 F.3d 358 (3d Cir. 1999) (substantial evidence standard in Social Security appeals)