While the claimant seeking Social Security Disability benefits in Plant v. Commissioner of Social Security was not successful, the court’s opinion in this case provides useful information for other persons seeking benefits about how to prove that a mental or physical impairment (or combination of impairments) is sufficiently severe.
The Social Security Administration (SSA) denied Plaintiff Dennis Plant’s claim for Disability benefits, in which he asserted that he was unable to work due to a number of physical impairments affecting his back, shoulder, hands and knee. Plaintiff appealed this decision, appearing at an administrative hearing before an SSA Administrative Law Judge (ALJ). Following the hearing, the ALJ ruled that Plaintiff was not disabled for benefits purposes because his impairments were not severe and imposed only minimal limitations on his ability to work.
On further appeal in the U.S. District Court for the Northern District of New York, Plaintiff argued that the ALJ erred in finding that his impairments were not severe.
In a disability benefits case, simply showing that the claimant has been diagnosed with a disease or impairment is not enough to prove that he or she is disabled and entitled to benefits. Rather, it is the claimant’s responsibility to prove that he or she suffers from a severe impairment and that the claimant is not able to work for at least a year as a result. Severe means “any impairment or combination of impairments which significantly limits [the claimant’s] physical or mental ability to do basic work activities,” the court explained. SSA regulations provide that work activities are “the abilities and aptitudes necessary to do most jobs.” Related to physical impairments, that includes activities like walking, standing, pushing, pulling and lifting.
Here, the court found that substantial evidence supported the ALJ’s finding that Plaintiff’s impairments were not severe. Although Plaintiff provided a variety of documentation detailing his impairments, the court found that “the record depicts an individual who is able to perform the physical functions necessary for most jobs despite those ailments.”
Plaintiff testified at the administrative hearing that he could walk up to a mile and perform basic lifting, pushing and pulling tasks after sufficient stretching. He also said that he could sit for 15-20 minutes at a time. In an Adult Functioning Report, meanwhile, Plaintiff indicated that he performs basic household tasks, cares for his dogs and mows his lawn, tasks the Court said suggested that he could still work. Furthermore, the Court noted that Plaintiff continued to work as a corrections officer after the date when he said he had become disabled in his initial benefits application. As a result, the Court affirmed the ALJ’s decision to deny benefits.
As this case shows, a person seeking Social Security Disability benefits must show that he or she suffers from one or more severe impairments rendering the claimant unable to work for a year or more. This requires clear and convincing evidence, including medical records, doctors opinions, work history information and often claimant testimony. An experienced Disability lawyer can assist by gathering the necessary documentation, presenting it to the SSA in the most convincing manner and explaining a client’s case at an administrative or appellate hearing, if necessary.
Related blog posts:
Severe Impairment in Social Security Disability Cases – Parker-Grose v. Astrue
Social Security Judges Must Take All of a Claimant’s Limitations into Account – March v. Commissioner of Social Security
In Social Security Disability Cases, Don’t Give Up – Rife v. Commissioner of Social Security