New York Court Reverses Social Security Disability Case for "Significant Legal Errors" - Raja v. Astrue

September 09,2014
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Sometimes the Social Security Administration (SSA) just plain gets it wrong. Raja v. Astrue, a New York Social Security disability case, is an example of one of those times.

Mahmood Raja worked as an auto mechanic from 1992 to 2007, when he stopped working due to the effects of heart disease, as well as COPD, hypertension and diabetes mellitus. He filed a claim for Social Security Disability Insurance and Supplemental Security Income, asserting that he’s no longer able to work due to the impairments. The SSA initially denied the claim, and Plaintiff later appeared at an administrative hearing before and SSA Administrative Law Judge.
Following the hearing, the ALJ found that Plaintiff was not disabled for benefits purposes. Although he suffered from severe impairments which prevented him from returning to his previous work, the ALJ found that Plaintiff retained the residual functional capacity (RFC) to perform a full range of light work. Using the “grids,” which compute whether a person can find work based on physical limitations, age, education and experience, the judge found that Plaintiff could perform jobs existing in significant numbers in the national economy.
In reaching this decision, the ALJ discounted the opinion of Plaintiff’s primary care physician, Dr. Verma, who said Plaintiff was “precluded from engaging in activities at a full sedentary level of exertion.” The ALJ also ignored the opinion of Plaintiff’s cardiologist, Dr. Sindhwani, who said Plaintiff could sit for only two hours in an eight hour workday, could lift less than 10 pounds on occasion and would need to take half hour breaks every two to three hours. Rather, the judge credited a disability analysis performed by a non-medical analyst who concluded that Plaintiff could perform a full range of light work.
“It is undisputed that the ALJ made significant legal errors in rendering his decision,” the U.S. District Court for the Southern District of New York ruled on appeal, noting that even the SSA agreed that the ALJ improperly rejected Dr. Verma’s opinion and ignored Dr. Sindhwani’s opinion. In determining the jobs that Plaintiff could perform despite his impairments, the ALJ also erred in assessing Plaintiff as being able to communicate in English. In fact, Plaintiff – who was born in Pakistan, where he obtained fifth-grade level education – had only limited English communication ability.

Plaintiff argued that there was sufficient evidence in the record to show that he was disabled and entitled to benefits, while the SSA claimed that the case should be remanded back to the ALJ to allow the judge to reconsider the medical opinions. Noting that both Verma and Sindhwani were Plaintiff’s treating physicians, whose opinions were entitled to “controlling weight” if properly supported, the Court found that there was substantial evidence showing that Plaintiff should be awarded benefits. The Court remanded the case back to the ALJ simply for a calculation of benefits owed.
As this case shows, even a claimant who seemingly does everything right – submitting clear and accurate medical records establishing disability – can be required to follow out the claim process to the very end in order to get benefits. We have said it before: we believe the initial denial is often intended to discourage claimants. A claimant with a strong claim should see out the process, through the ALJ hearing and possibly a federal appeal. An experienced Social Security disability lawyer can provide vital assistance along the way.
Related blog posts:
In Social Security Disability Cases, Don’t Give Up – Rife v. Commissioner of Social Security
Disabled or Not Disabled: In Social Security Cases, That is The Question – Small v. Commissioner of Social Security
Doctor Opinions in Social Security Disability Cases: Which Ones are Treating Physicians? Ash v. Commissioner of Social Security