New Jersey Court Reverses Disability Benefits Denial for Failure to Consider Claimant Testimony - Troy v. Commissioner of Social Security

 In Social Security disability cases, medical evidence - doctor's opinions, treatment records, objective clinical studies etc. - is the key to winning a claim. That is, a clear and accurate record showing that the claimant suffers from an impairment or combination of impairments affecting his or her ability to work makes it more likely that a claim will ultimately be approved. In Troy v. Commissioner of Social Security, however, the District Court for the District of New Jersey explains that medical evidence is not the only thing that a Social Security judge must consider in reaching a decision on a disability benefits claim.

Plaintiff Candace Troy received Social Security disability benefits from 1976 to 1981. In 2007, she filed a claim for retroactive benefits related to a disability period that began in 1991. Plaintiff asserted that she's been unable to work since that time as a result of depression and personality disorder.

The Social Security Administration (SSA) denied the claim and Plaintiff later appeared before an SSA Administrative Law Judge (ALJ) at an administrative hearing.https://askcompetentlawyer.com/complex-litigation/The ALJ found that Plaintiff was not disabled for benefits purposes because the claim was based on "spotty and general notes" from Plaintiff's doctors that were not sufficient to show that she suffered from a severe impairment.

On appeal, the District Court reversed the ALJ's decision, finding that he failed to consider all of the evidence Plaintiff provided, including Plaintiff's own testimony. In concluding whether a benefits claimant suffers from a severe impairment, the court explained

the ALJ must take into account all of the evidence, including Plaintiff's symptoms, to determine whether the functionally limiting effects of [claimant's] impairments have an effect on their ability to perform basic work activities.

According to the court, the ALJ must specifically consider Plaintiff's testimony regarding her symptoms and compare it to objective medical evidence. In so doing, the ALJ must make findings that are sufficiently clear to allow a subsequent reviewer to determine the weight afforded to the Plaintiff's testimony.