The repeated denials of one veteran’s Social Security Disability Insurance benefits application have been the subject of our past few posts. The veteran suffered from PTSD and an ALJ failed to initially consider the veteran’s mental condition in an administrative hearing. A magistrate judge sent the veteran’s case back to reconsideration by the ALJ and the ALJ still found that the veteran had the residual functional capacity to perform work.
The magistrate judge reviewed the ALJ’s second denial of benefits and decided to uphold it. Both the magistrate judge and the ALJ found that the veteran’s PTSD was severe but oddly found that the PTSD did not impair the veteran’s residual functional capacity. The magistrate rejected the veteran’s challenges to the ALJ’s adverse credibility determination mostly because there was no medical evidence to contradict the ALJ’s decision that the veteran was not being forthcoming about the severity of his symptoms.
A federal appeal of the ALJ’s decision was filed. The veteran claimed that the ALJ erred by finding that his PTSD was a severe impairment but then concluding that this impairment did not impact his ability to work. The appeals court noted that this inconsistency was an interesting issue but declined to address it because there was an alternative reason to uphold the ALJ’s decision.
The ALJ completed two analyses when denying the veteran’s claim – the ALJ first decided that the PTSD did not impact the veteran’s ability to work and then did an alternative analysis including the limitations in social interaction posed by the PTSD. Because the ALJ would have found the veteran capable of working even with his PTSD symptoms, the court decided that benefits were not warranted.
Source: US Court of Appeals 7th Cir., “Guranovich v. Astrue,” Feb. 14, 2012