Carty v. Sullivan

736 F. Supp. 1414, 1990 U.S. Dist. LEXIS 5908, 1990 WL 64023
CourtDistrict Court, W.D. Virginia
DecidedApril 27, 1990
DocketCiv. A. No. 86-0120-B
StatusPublished

This text of 736 F. Supp. 1414 (Carty v. Sullivan) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carty v. Sullivan, 736 F. Supp. 1414, 1990 U.S. Dist. LEXIS 5908, 1990 WL 64023 (W.D. Va. 1990).

Opinion

MEMORANDUM OPINION

GLEN M. WILLIAMS, Senior District Judge.

The plaintiff has filed a motion to alter or amend this court’s order of March 27 granting summary judgment to the defendant. For the first time her counsel has raised the issue of whether the Administrative Law Judge (AU) erred in not considering Mrs. Carty’s residual functional capacity in determining whether she was eligible for benefits.

As the court stated in its memorandum opinion, a widow, to receive benefits, must demonstrate the presence of a disability under 42 U.S.C. § 423(d). Section 423(d)(2)(B) states that:

A widow ... shall not be determined to be under a disability ... unless ... her physical or mental impairment or impairments are of a level of severity which under regulations prescribed by the Secretary is deemed to be sufficient to preclude an individual from engaging in any gainful activity. (Emphasis added).

This is in contrast to § 423(d)(2)(A), applicable to wage earners, which requires only a showing that the claimant is incapable of substantial gainful activity. The Act intentionally places a stricter standard of disability on widows1 than it does wage earners. Lewis v. Schweiker, 720 F.2d 487, 488 (8th Cir.1983).

This court outlined the regulations governing widows’ claims promulgated by the Secretary in Honaker v. Heckler, 603 F.Supp. 1308 (W.D.Va.1985), as follows:

Both 20 C.F.R. § 404.1501 et seq. and § 416.901 et seq. provide the pertinent regulatory framework. The general rules for evaluating disability are set forth in §§ 404.1520 through 404.1523 and §§ 416.920 and 416.923 respectively. These rules have commonly been referred to as the sequential evaluative process. That process includes, should the evidence so compel, a consideration of whether a claimant’s impairment(s) is severe. 20 C.F.R. §§ 404.1520(c) and 404.1521; 20 C.F.R. § 416.920(c) and 416.921.
Carved out of the sequential evaluative process, however, are the considerations to be made in determining disability for widows, widowers and surviving divorced spouses. 20 C.F.R. § 404.1577 through § 404.1580. As stated, in order for a surviving widow to qualify, her impairment, either physical or mental, must reach a level of severity that prevents her from doing any gainful activity. 20 C.F.R. § 404.1577. A widow will be found disabled if her impairment(s) meets specific clinical findings that are set forth in the Secretary’s Listings of Impairments, 20 C.F.R. § 404.1525, appendix 1, or constitute the medical equivalence of those set forth in the Listings. In addition, the impairment must meet the durational requirements of the Act. 20 C.F.R. § 404.1578. Therefore, the initial steps in the sequential evaluative process, i.e., determining whether the claimant is engaged in substantial gainful activity or has a severe impairment or combination thereof, are not determina[1416]*1416tive considerations; the only consideration being whether the claimant’s impairments) meets or equals the listing for the durational limit.

Id. at 1309.

As opposed to wage earners, widows must prove their inability to engage in any work activity under medical considerations alone. Wage earners must prove only their inability to engage in substantial gainful activity, and may use both medical and non-medical proof. Hudson v. Sullivan, 717 F.Supp. 340, 345 (W.D.Pa. 1989) citing Smith v. Schweiker, 671 F.2d 789 (3rd Cir.1982).

Counsel for the claimant has drawn the court’s attention to Kier v. Sullivan, 888 F.2d 244 (2d Cir.1989), in which the Second Circuit held that the Secretary had to consider a widow’s residual functional capacity before finding that she was incapable of performing any gainful activity. Id. at 247. Kier followed Tolany v. Heckler, 756 F.2d 268 (2d Cir.1985), in which the Second Circuit first suggested that something was amiss with the Secretary’s method of evaluating widows’ disability claims. The court set out the five-step procedure used by the Secretary to determine a wage-earner’s disability as it was summarized in City of New York v. Heckler, 742 F.2d 729 (2d Cir.1984):

The first step in the sequential process is a decision whether the claimant is engaged in “substantial gainful activity.” If so, benefits are denied. 20 C.F.R. §§ 404.1520(a), (b), 416.920(a), (b) (1983). If not, the second step is a decision whether the claimant’s medical condition or impairment is “severe.” If not, benefits are denied. 20 C.F.R. §§ 404.1520(c), 416.920(c). If the impairment is “severe,” the third step is a decision whether the claimant’s impairments meet or equal the “Listing of Impairments” set forth in subpart P, app. 1, of the social security regulations, 20 C.F.R. §§ 404.-1520(d), 416.920(d). These are impairments acknowledged by the Secretary to be of sufficient severity to preclude gainful employment. If a claimant’s conditions meets or equals the “listed” impairments, he or she is conclusively presumed to be disabled and entitled to benefits. If the claimant’s impairments do not satisfy the “Listing of Impairments,” the fourth step is assessment of the individual’s “residual functional capacity,” i.e., his capacity to engage in basic work activities, and a decision whether the claimant’s residual functional capacity permits him to engage in his prior work. If the residual functional capacity is consistent with prior employment, benefits are denied. 20 C.F.R. §§ 404.1520(e), 416.920(e). If not, the fifth and final step is a decision whether a claimant, in light of his residual functional capacity, age, education, and work experience, has the capacity to perform “alternative occupations available in the national economy.” Decker v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
736 F. Supp. 1414, 1990 U.S. Dist. LEXIS 5908, 1990 WL 64023, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carty-v-sullivan-vawd-1990.