DeLong applied for DIB and SSI in 2003, both of which the Social Security Administration (Agency) denied on initial review. Although she subsequently obtained three hearings before an administrative law judge (ALJ), the ALJ concluded after each hearing that DeLong was not disabled. The Agency’s Appeals Council twice intervened, vacating the ALJ’s decision and remanding DeLong’s case for further administrative proceedings after the first and second hearings. After the ALJ’s third determination that DeLong was not disabled, however, the Appeals Council declined further review. Consequently, the ALJ’s determination became the Commissioner’s final decision.
On October 27, 2010, DeLong filed a complaint in the United States District Court for the Western District of Michigan to challenge the denial of benefits. Relying on 42 U.S.C. §§ 405(g) and 1383(c)(3), she asserted three grounds for relief: (1) that the Commissioner erred in relying on a consulting medical source rather than the opinions of DeLong’s treating physicians; (2) that the Commissioner improperly assessed other medical source opinions and lay testimony; and (3) that the Commissioner erred in assessing DeLong’s credibility and mischaracterized the evidence in the record. The District Court rejected the second and third claims out of hand, noting that “[c]redibility determinations . . . are peculiarly within the province of the ALJ,” explaining that the ALJ had not mischaracterized any of the underlying medical evidence, and finding no error in the ALJ’s consideration of lay opinion evidence. But, concluding that the ALJ had “failed to provide ‘good reasons’ for the weight he gave to the opinions of [DeLong’s] treating physicians,” the District Court vacated the denial of benefits and remanded DeLong’s case for further administrative proceedings under sentence four of § 405(g).
Judge(s): Bernice B. Donald
Jurisdiction: U.S. Court of Appeals, Sixth Circuit
Related Categories: Administrative Law , Contracts , Government / Politics , Insurance , Securities
|Circuit Court Judge(s)|
|Appellant Lawyer(s)||Appellant Law Firm(s)|
|Paul Jensen||Jensen De Haan & Symko PC|
|Nicholas Romer||Jensen De Haan & Symko PC|
|Benjamin Symko||Jensen De Haan & Symko PC|
|Appellee Lawyer(s)||Appellee Law Firm(s)|
|Niranjan Emani||Social Security Administration|