3:24-cv-01782
D. Conn.Aug 29, 2025Background
- Plaintiff Nehemiah W. appealed the denial of his applications for Social Security Disability Insurance (DIB) and Supplemental Security Income (SSI) after a 2017 workplace injury resulted in chronic back pain and other impairments.
- His applications were denied at the initial and reconsideration stages. He alleged disability based on epilepsy, degenerative back disease, anxiety, and depression.
- The ALJ found several severe impairments but determined the plaintiff could perform past relevant work and other jobs, denying benefits.
- Plaintiff challenged the ALJ’s decision, arguing improper development of the administrative record, especially absence of certain medical records and failure to consider crucial non-medical evidence about his functional limitations at work.
- The District Court reviewed whether the ALJ applied correct legal standards and whether the decision was supported by substantial evidence.
- The Court granted the plaintiff’s motion for remand, finding legal error in the ALJ’s failure to fully develop the record and properly consider key vocational evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of ALJ's record development | ALJ did not secure a treating provider opinion or missing physical therapy records, so RFC lacked support | Well-supported consultative/state agency exam opinions are sufficient, no further duty to develop | ALJ failed to fully develop the record; remand required |
| Consideration of DORS vocational evaluation | ALJ ignored significant DORS evidence of functional limitations | ALJ was not required to rely on non-acceptable medical sources; addressed DORS letter generally | ALJ erred by failing to consider supplemental DORS evidence |
| Reliance on consultative opinions with factual errors | Opinions relied on wrong individual/factual confusion, undermining RFC finding | No prejudice as ALJ did adequate evaluation, plaintiff responsible for record | ALJ should have further clarified or corrected such opinions |
| Inclusion of all relevant evidence in RFC assessment | RFC failed to reflect work limitations and break requirements per record | ALJ’s RFC based on permissible non-medical and medical evidence | RFC lacked support due to incomplete record, supporting remand |
Key Cases Cited
- Richardson v. Perales, 402 U.S. 389 (1971) (defining the substantial evidence standard for review of Social Security decisions)
- Brault v. Soc. Sec. Admin., Comm’r, 683 F.3d 443 (2d Cir. 2012) (substantial evidence standard applies to Social Security appeals)
- Perez v. Chater, 77 F.3d 41 (2d Cir. 1996) (ALJ's affirmative duty to develop the record applies even with claimant’s counsel)
- Burgess v. Astrue, 537 F.3d 117 (2d Cir. 2008) (ALJ’s duty to fully develop the record is independent of representation)
- Balsamo v. Chater, 142 F.3d 75 (2d Cir. 1998) (ALJ cannot substitute their own judgment for competent medical opinion)