Garcia v. Comm's of Soc. Sec., No. 12-15686 (9th Cir. 2014)
Annotate this CasePlaintiff appealed the denial of social security benefits on the basis that she was not intellectually disabled. Plaintiff had received social security benefits because of her intellectual disability but the SSA concluded that she no longer qualified as disabled once she reached the age of 18. The court concluded that the ALJ had a duty to order further IQ testing and the ALJ's failure to do so was not harmless error. Accordingly, the court reversed and remanded for further proceedings.
Court Description: Social Security. The panel reversed the district court’s order affirming the Commissioner of Social Security’s denial of benefits on the basis that the claimant was not intellectually disabled. The panel held that the administrative law judge (“ALJ”) had a duty to order further IQ testing, and concluded that the ALJ’s failure to do so was error that cannot be considered harmless. The panel remanded to the district court with instructions to reverse the final decision of the Commissioner and to order the Commissioner to develop the record through further IQ testing. Judge O’Scannlain dissented because he believed that the majority erroneously presumed that the Commissioner’s ostensible error prejudiced the claimant. Judge O’Scannlain also was unconvinced that the ALJ erred by not ordering a new and complete round of IQ tests.
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