By Dan Menken
Last Tuesday, in Reid v. Commissioner of Social Security, the Fourth Circuit evaluated the Social Security disability benefit claims of Brian Edward Reid under Title II of the Social Security Act, 42 U.S.C. §§ 401-434. Reid filed for disability benefits on December 7, 2006, alleging that he became unable to work on June 4, 2004, when he fell of a roof during work and suffered two spinal fractures. This original claim was denied.
A hearing was then conducted before an administrative law judge (“ALJ”), who ruled that because Reid could engage in sedentary work, he was not disabled. On review of the decision, the Appeals Council remanded the case, ordering the ALJ to consider the evidence from June 4, 2004, forward, which the ALJ had not done because he thought that res judicata applied to the 2004-2006 period. The Appeals Council also instructed the ALJ to consider the effect of Reid’s mental impairments and obesity on his disability claims. After a second hearing on January 18, 2011, Reid was denied benefits for a second time. Reid again appealed to the Appeals Council, which largely adopted the ALJ’s findings.
On this appeal to the Circuit Court, Reid contended that (1) the Commissioner ignored several years of his medical history and (2) the Commissioner failed to consider the combined effects of his multiple impairments. In reviewing the district court’s judgment de novo, the Court of Appeals reviewed the Commissioner’s decision for substantial evidence.
In considering Reid’s first claim, the Court ruled that the Commissioner’s decision satisfied the statutory requirements because the Commissioner had stated that the whole record had been considered. Without evidence to the contrary, the Court decided to take the Commissioner at her word. In support of this ruling, the Court remarked that Reid had failed to point to any specific piece of evidence that, if considered, might have changed the outcome of his disability claim.
In regards to the second claim, the Court ruled that the ALJ had specifically contemplated the combinatorial effects of Reid’s various impairments as required by statute and complied with guidance set out in Walker, which states that the ALJ must “adequately explain his or her evaluation of the combined effects of [a claimant’s] impairments.” Even after considering the combined effects of the claimant’s impairments, the ALJ ruled that the combined impairments did not “equal in severity” to an impairment listed under Title II of the Social Security Act.