Lawrence Hallaron, III v. Social Security Administ

578 F. App'x 350
CourtCourt of Appeals for the Fifth Circuit
DecidedAugust 13, 2014
Docket13-31065
StatusUnpublished
Cited by6 cases

This text of 578 F. App'x 350 (Lawrence Hallaron, III v. Social Security Administ) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lawrence Hallaron, III v. Social Security Administ, 578 F. App'x 350 (5th Cir. 2014).

Opinion

PER CURIAM: *

Lawrence Hallaron, III, appeals the district court’s dismissal of his complaint challenging an adverse decision of the Acting Commissioner of Social Security (Commissioner). We reverse and remand.

I

In 1989, an Administrative Law Judge (ALJ) found Hallaron disabled and entitled to supplemental security income under Title XVI of the Social Security Act (the Act), 42 U.S.C. § 1381 et seq., effective 1987. 1 The Commissioner conducts periodic continuing disability reviews (CDRs) to determine whether recipients remain entitled to benefits. 2 Absent certain exceptions not relevant to this case, 42 U.S.C. § 1382c(a)(4)(A) provides that the Commissioner may only cease providing benefits if substantial evidence demonstrates both that there has “been any medical improvement in the individual’s impairment” and that “the individual is now able to engage in substantial gainful activity.” 3 Agency regulations define “medical improvement” as “any decrease in the medical severity of [the recipient’s] impairments) which was present at the time of the most recent favorable medical decision that [he or she was] disabled or continued *352 to be disabled.” 4 Because the medical improvement determination requires examination of the “most recent favorable medical decision,” agency regulations provide a procedure in the event the file regarding that decision cannot be located. 20 C.F.R. § 416.994(b)(2)(iv)(E) provides:

If the prior file cannot be located, we will first determine whether you are able to now engage in substantial gainful activity based on all your current impairments .... If you are able to engage in substantial gainful activity, we will determine whether an attempt should be made to reconstruct those portions of the missing file that were relevant to our most recent favorable medical decision (e.g., work history, medical evidence from treating sources and the results of consultative examinations). This determination will consider the potential availability of old records in light of their age, whether the source of the evidence is still in operation, and whether reconstruction efforts will yield a complete record of the basis for the most recent favorable medical decision. If relevant parts of the prior record are not reconstructed either because it is determined not to attempt reconstruction or because such efforts fail, medical improvement cannot be found. 5

In 1997, a continuing disability review of Hallaron resulted in a determination that his disability continued (the 1997 CDR). 6 A second continuing disability review in 2009, however, found that Hallaron’s disability had ceased. 7 A state hearing officer upheld the cessation of benefits. 8 Hal-laron sought review of the decision before an ALJ. The ALJ found that “the file containing the evidence utilized in the most recent favorable decision [i.e., the 1997 CDR] could not be located” and that “[c]urrent review of all documentation in the available files does not yield a clear indication of the evidence or conclusion on which the most recent favorable determination was based.” 9 Rather than decide whether an attempt should be made to reconstruct the file, however, the ALJ proceeded to examine whether “there is evidence of current disability.” 10 Finding that Hallaron was not disabled, the ALJ affirmed the cessation of benefits. 11

Following the Appeals Council’s denial of review, Hallaron filed the instant suit. 12 The district court denied Hallaron’s motion for summary judgment and dismissed his complaint with prejudice. 13 The court concluded, inter alia, that, while medical improvement cannot be found when the Commissioner is unable to locate the recipient’s most recent favorable determination, such a finding is not a condition precedent to the cessation of benefits. 14 Rather, in such an instance, the Commissioner is permitted to examine the recipient’s condition as though he is filing a new application. 15 This appeal followed.

II

“Our review of the Commissioner’s decision is limited to two inquiries: (1) *353 whether the decision is supported by substantial evidence on the record as a whole, and (2) whether the Commissioner applied the proper legal standard.” 16 The Commissioner concedes that both the district court and the ALJ erred in terminating Hallaron’s benefits. 17 We agree. As previously noted, the Act specifically states that, absent exceptions not relevant here, 18 a claimant’s benefits may be terminated only if substantial evidence demonstrates both that, “there has been any medical improvement” and that “the individual is now able to engage in substantial gainful activity.” 19 This plain language unequivocally dictates that benefits may not be terminated without a finding of medical improvement. As the district court recognized, “20 C.F.R. § 416.994(b)(2)(iv)(E) precludes a finding of medical improvement when the file upon which the claimant’s most recent favorable determination of benefits was based cannot be found and is not reconstructed.” 20

Although the ALJ found that “the file containing the evidence utilized in the most recent favorable decision could not be located,” the ALJ proceeded to analyze Hallaron’s entitlement to benefits based upon “whether there [was] evidence of current disability.” 21 The ALJ did not consider whether there was any medical improvement since the most recent favorable decision in 1997 or whether an attempt should be made to reconstruct the file pertaining to the 1997 CDR. 22 Accordingly, the Commissioner’s decision was based on the application of an improper legal standard, and the district court erred in dismissing Hallaron’s complaint.

Ill

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Bluebook (online)
578 F. App'x 350, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lawrence-hallaron-iii-v-social-security-administ-ca5-2014.