Sprague v. Heckler

595 F. Supp. 1380, 1984 U.S. Dist. LEXIS 23190
CourtDistrict Court, D. Maine
DecidedSeptember 28, 1984
DocketCiv. No. 83-0038 P
StatusPublished
Cited by1 cases

This text of 595 F. Supp. 1380 (Sprague v. Heckler) is published on Counsel Stack Legal Research, covering District Court, D. Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sprague v. Heckler, 595 F. Supp. 1380, 1984 U.S. Dist. LEXIS 23190 (D. Me. 1984).

Opinion

MEMORANDUM OF DECISION AND ORDER

GENE CARTER, District Judge.

This is an action brought under 42 U.S.C. §§ 405(g), 1383(c)(3) for review of the final decision of the Secretary of Health & Human Services which affirmed the termination of Plaintiff Kenneth Sprague’s disability insurance benefits and supplemental security income benefits. Sprague is a thirty-one year old man who became disabled commencing on December 1, 1974. His benefits were terminated administratively as of February 19,1982. At the request of the claimant, a hearing was held before an Administrative Law Judge (ALJ). The AU found that the claimant suffered a sociopathic personality disorder of a mild to moderate degree. He found that this impairment did not significantly limit the claimant’s ability to perform basic work activities and thus was not severe as required by 20 C.F.R. §§ 404.1521, 416.921. The Appeals Council affirmed the AU’s decision.

Sprague filed a complaint in this Court. He sought: (1) review of the final decision of the Secretary; (2) certification of the action as a class action; (3) a declaration that standards applied by the Secretary to determine mental disabilities violate the Social Security Act; and (4) appropriate injunctive relief. After Plaintiff Charles Jordan intervened as a named plaintiff, and while Plaintiffs’ motion for class certification was still pending, Plaintiff Sprague moved individually for summary judgment. In response, the Secretary filed a Motion for an Order Affirming the Decision of the Secretary. These motions are currently before the Court.

In reviewing the termination of disability benefits, the standard of this Court’s review is whether the determination made by the ALJ is supported by substantial evidence. 42 U.S.C. § 405(g); Lizotte v. Secretary of Health & Human Services, 654 F.2d 127, 128 (1st Cir.1981). In other words, the determination must be supported by such relevant evidence as a reasonable mind might accept as adequate to support the conclusions drawn. Richardson v. Perales, 402 U.S. 389, 401, 91 S.Ct. 1420, 1427, 28 L.Ed.2d 842 (1971).

Plaintiff presents three arguments: (1) the ALJ’s finding that his impairment is not “severe” is not supported by substantial evidence; (2) the ALJ applied the wrong legal standard when making a determination of “severity”; and (3) the “severity” regulation conflicts with the Social Security Act because it precludes consideration of vocational factors. The Court has thoroughly reviewed the entire record, including the transcript of the hearing below, the exhibits and the briefs submitted by counsel. After careful consideration, the Court has determined that the case shall be remanded to the Secretary for application of the correct legal standard with respect to “severity.” Under these circumstances, the question whether the “severity” regulation conflicts with the Social Security Act is not reached.

The regulations set forth a sequential analysis containing five steps for evaluating disability claims. See 20 C.F.R. § 404.1520; Goodermote v. Secretary of Health & Human Services, 690 F.2d 5, 6-7 (1st [1382]*1382Cir.1982). At issue in this case is the second step, which is embodied in 20 C.F.R. § 404.1520(c):

(c) You must have a severe impairment. If you do not have any impairments) which significantly limits your physical or mental ability to do basic work activities, we will find that you do not have a severe impairment and are, therefore, not disabled. We will not consider your age, education, and work experience. However, it is possible for you to have a period of disability for a time in the past even though you do not now have a severe impairment.

An impairment is “severe” if it significantly limits a claimant’s physical or mental abilities to do basic work activities. Id. at § 404.1521(a). Basic work activities are “the abilities and aptitudes necessary to do most jobs.” Id. at § 404.1521(b). Examples of basic work activities listed in the regulations are:

(1) Physical functions such as walking, standing, sitting, lifting, pushing, pulling, reaching, carrying, or handling;
(2) Capacities for seeing, hearing, and speaking;
(3) Understanding, carrying out, and remembering simple instructions;
(4) Use of judgment;
(5) Responding appropriately to supervision, co-workers and usual work situations; and
(6) Dealing with changes in a routine work setting.

Id. at § 404.1521(b).

The subject of all the medical documents and most of the testimony was Plaintiff’s mental impairment.1 Thus, the ALJ’s obligation was to determine whether Plaintiff’s mental disability impaired his ability to perform the functions listed in § 404.1521(b). The record demonstrates that Plaintiff has a long history of drug abuse, but he. had taken no drugs other than Valium in the three years prior to his hearing. He is administered Valium by prescription to help control his emotional instability. He easily becomes frustrated, angry and explosive. He has difficulty dealing with stressful situations. He has in the past been diagnosed as a paranoid schizophrenic. There is apparently no question, however, about his intellectual abilities. These facts call into question Plaintiff’s ability to perform only one of the groups of activities listed in the regulations: “responding appropriately to supervision, co-workers and usual work situations.” § 404.1521(b)(5). This should have been the focus of the ALJ’s inquiry with respect to severity.

The findings of the ALJ were:

The medical evidence of record, the testimony given by the claimant, and the testimony of the Medical Advisor establishes to the satisfaction of the undersigned that as of the date of the hearing in this matter the claimant’s impairment does not significantly affect his physical or mental abilities to walk; stand; sit; lift; push; pull; reach; carry; handle objects; see; hear; speak; understand, carry out, and remember simple instructions; use judgment; concentrate; or comprehend. Furthermore, there is only a moderate degree of impairment of his ability to relate to other people; only a moderate degree of restriction of his normal daily activities; and only a moderate degree of constriction of his interests.

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Related

Sprague v. Heckler
595 F. Supp. 1383 (D. Maine, 1984)

Cite This Page — Counsel Stack

Bluebook (online)
595 F. Supp. 1380, 1984 U.S. Dist. LEXIS 23190, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sprague-v-heckler-med-1984.