Court Says SSA Must Consider Disability Claimant's Back Condition - Laframboise v. Commissioner of Social Security

September 15,2009
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Sometimes, a person seeking Social Security Disability benefits is unable to work due to one single physical or mental condition. Other times, a claim may be based on the combined effects of an array of impairments on the claimant’s capacity to continue working. In these cases, as the U.S. District Court for the Northern District of New York explains in Laframboise v. Commissioner of Social Security, the Social Security Administration and its judges must consider the effects of each and every impairment on the claimant’s ability to work.

Mr. Laframboise filed a claim for disability benefits with the SSA, asserting that he is unable to work due to heart disease as well as a lower back condition, carpal tunnel syndrome and knee pain. The SSA initially denied the claim and, following a hearing, an SSA Administrative Law Judge found that Laframboise was not disabled for benefits purposes. Although his coronary artery disease and related heart ailments were a severe impairment that significantly limited Laframboise’s ability to work, the ALJ found that he retained the residual functional capacity to perform a full range of sedentary work.

In reaching the decision, the ALJ concluded that Laframboise’s lower back condition, carpal tunnel syndrome and knee pain were not severe impairments. The judge also rejected Laframboise’s statements regarding to what extent his impairments limited him; finding that the allegations were not entirely credible.

The District Court reversed the decision on appeal, ruling that the ALJ neglected to consider the limiting effects of Laframboise’s back condition on his ability to work and wrongly rejected opinions by Laframboise’s treating physician.

The court noted that the majority of the medical evidence that Laframboise submitted in support of his claim related to his heart condition and only a “modest amount” of evidence referenced his back impairment. Nevertheless, the evidence in the record was sufficient to show that back problems limited Laframboise’s ability to work. The court explained that “Notwithstanding the scarcity of evidence revealing medical treatment for plaintiff’s back condition, the court cannot overlook the medical source statement provided by Dr. Calabrese, his treating physician, … in which he opines that the back condition does restrict plaintiff’s ability to lift, carry, stand, sit and walk, in addition to presenting postural limitations.”

Combined with notes from a physical therapist who treated Laframboise, the court concluded that the evidence was sufficient to show that the back condition may have placed significant restrictions on his ability to work. According to the court, the ALJ erred by not considering this evidence in finding that Laframboise’s RFC allowed him to do sedentary jobs. The court remanded the case back to the ALJ for further proceedings.

With more than 40 years of combined experience representing clients in disability claims in New York, Connecticut and New Jersey, the Social Security Disability lawyers at Hermann Law Group, PLLC regularly handle cases involving a claimant who suffers from more than one physical or mental impairment or a combination of both physical and mental impairments. We understand what the SSA is looking for and we know how to present a claim in the most compelling possible manner.