Rossiter v. SSA

2011 DNH 115
CourtDistrict Court, D. New Hampshire
DecidedJuly 15, 2011
DocketCV-10-349-JL
StatusPublished
Cited by5 cases

This text of 2011 DNH 115 (Rossiter v. SSA) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rossiter v. SSA, 2011 DNH 115 (D.N.H. 2011).

Opinion

Rossiter v. SSA CV-10-349-JL 7/15/11

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Cindy A. Rossiter

v. Civil No. lO-cv-349-JL Opinion No. 2011 DNH 115 Michael J. Astrue, Commissioner, Social Security Administration

MEMORANDUM ORDER

This is appeal from the denial of Cindy A. Rossiter's claim

for Social Security Disability Insurance Benefits ("DIB"). It

presents the question of whether an administrative law judge

("ALU") at the Social Security Administration ("SSA") can reject

such a claim by determining that the applicant was not disabled

as of her date last insured without consulting a medical advisor,

even when the determination rests on ambiguous evidence.1 This

court has subject-matter jurisdiction under 42 U.S.C. § 405(g)

(Social Security).

Rossiter argues that the ALU's approach violates an SSA

Policy Statement, "SSR 83-20." See Social Security Ruling 83-20,

Program Policy Statement: Titles II and XVI: Onset of Disability

1A "[c]laimant is not entitled to [DIB] unless he can demonstrate that his disability existed prior to the expiration of his insured status," i.e., his date last insured. Cruz Rivera v. Sec'y of HHS, 818 F.2d 96, 97 (1st Cir. 1986). A claimant's date last insured is a function of his or her age and earnings history. See 20 C.F.R. §§ 404.130, 404.132. (PPS-100), 1983 WL 31249 (S.S.A. 1983). This court agrees.

Accordingly, for the reasons set forth fully below, the court

grants Rossiter's motion to reverse the ALJ's decision and

remands the case for further consideration under SSR 83-20.

I. Background

Rossiter claimed she was disabled by a number of

impairments, including headaches, pain in her neck and upper

extremities, vision loss, and depression, as of her date last

insured, September 30, 2003. The ALJ found that as of that date

Rossiter was not engaged in substantial gainful activity, see 20

C.F.R. § 404.1571, and suffered from severe impairments, see id.

§ 404.1520(c), limited to degenerative disc disease, myofascial

pain syndrome, and degenerative changes to the left shoulder.

The ALJ went on to find, however, that as of September 30,

2003, these severe impairments did not meet or medically egual a

listed impairment, see id. § 404.1520(d), and that Rossiter had

the residual functional capacity to perform light work with

certain limitations (viz., no overhead reaching with her left arm

or work around dangerous machinery or extreme temperatures), see

id. § 404.1567(a). Thus, the ALJ found, while Rossiter could not

perform her past relevant work as of September 30, 2003, see id.

§ 404.1520(f), she could have performed jobs existing in the

2 national economy in significant numbers, see id. § 404.1560(c),

including small product assembler, cafeteria or school child care

attendant, addresser, or food and beverage order clerk. So the

ALJ concluded that as of Rossiter's date last insured she was not

disabled, see id. § 404.1520(g)(1), disentitling her to DIB, see

42 U.S.C. § 423(a)(1)(E). In reaching this decision, the ALJ

neither consulted a medical advisor nor determined whether

Rossiter was disabled as of the date of the hearing (as opposed

to her date last insured).

The SSA's Decision Review Board ("DRB") affirmed the ALJ's

ruling, see 20 C.F.R. § 405.440(c)(1), so that affirmance is the

final decision on Rossiter's claim, see id. § 405.440(b) (1),

which she has appealed to this court, see 42 U.S.C. § 405(g).

Rossiter has moved for an order reversing the decision, see L.R.

9.1(b)(1), while the Commissioner has cross-moved for an order

affirming it, see L.R. 9.1(d).

II . Applicable legal standard

"Judicial review of a Social Security claim is limited to

determining whether the ALJ used the proper legal standards and

found facts upon the proper guantum of evidence." Ward v. Comm'r

of Soc. Sec., 211 F.3d 652, 655 (1st Cir. 2000). So if the ALJ's

decision was based on "a legal or factual error," or otherwise

3 unsupported by substantial evidence, then it must be reversed and

remanded under § 405(g). Manso-Pizarro v. Sec'y of Health &

Human Servs., 76 F.3d 15, 16 (1st Cir. 1996).

Ill. Analysis

Rossiter argues that the ALJ made a legal error by finding

that she was not disabled as of her date last insured without

calling on the services of a medical advisor, in violation of SSR

83-20. SSR 83-20 states in relevant part that:

In some cases, it may be possible, based on the medical evidence to reasonably infer that the onset of a disabling impairment(s) occurred some time prior to the date of the first recorded medical examination . . . . How long the disease may be determined to have existed at a disabling level of severity depends on an informed judgment of the facts in the particular case. This judgment, however, must have a legitimate medical basis. At the hearing, the [ALJ] should call on the services of a medical advisor when onset must be inferred.

Id. at *3. As the court of appeals has observed, SSR 83-20 thus

"reguire[s] the ALJ to consult a medical advisor" when "the

evidence regarding the date on which [a] claimant's . . .

impairment became severe is ambiguous." May v. SSA Comm'r, 125

F.3d 841 (table), 1997 WL 616196, at *1 (1st Cir. Oct. 7, 1997);

see also, e.g., Grebenick v. Chater, 121 F.3d 1193, 1200-01 (8th

Cir. 1997); Ried v. Chater, 71 F.3d 372, 374 (10th Cir. 1995);

Bailey v. Chater, 68 F.3d 75, 79 (4th Cir. 1995).

4 The Commissioner argues that this requirement did not apply

here, for two reasons. First, he maintains, because the ALJ

never decided one way or the other whether Rossiter became

disabled after her date last insured, there was no onset date

about which to consult a medical advisor. Second, the

Commissioner asserts, there was no ambiguity about whether the

onset date of Rossiter's claimed disability preceded her date

last insured.2 The court rejects these arguments.

A. SSR 83-20 applies even though the ALJ did not decide whether Rossiter was disabled after her onset date

As the Commissioner acknowledges, his first argument against

applying SSR 83-20 has been expressly rejected by two other

judges of this court.

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