Rubin v. O'Malley, No. 23-540 (2d Cir. 2024)
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Plaintiff Michelle Rubin applied for Social Security Disability Insurance benefits in 2019, citing major depressive disorder as her disabling condition. An administrative law judge (ALJ) denied her claim, concluding that Rubin was not disabled under the Social Security Act. Rubin exhausted the administrative appeals process and subsequently challenged the final decision in the United States District Court for the Southern District of New York, which affirmed the denial of benefits.
The ALJ found that Rubin had not engaged in substantial gainful activity since her alleged onset date and had a severe impairment of major depressive disorder. However, the ALJ determined that Rubin did not meet the criteria for a listed impairment and had the residual functional capacity (RFC) to perform a full range of work with certain nonexertional limitations. The ALJ partially discounted the opinion of Rubin’s treating psychiatrist, Dr. Paul, who had opined that Rubin met the criteria for a listed impairment and was unable to work full-time. The ALJ also found that Rubin could not perform her past relevant work but could perform other jobs existing in significant numbers in the national economy.
The United States Court of Appeals for the Second Circuit reviewed the case and found that the ALJ’s decision was not supported by substantial evidence. The court noted that the ALJ had misinterpreted the medical and lay evidence, failing to appreciate the consistent narrative that supported Dr. Paul’s opinion. The court concluded that the ALJ erred in determining that Rubin did not meet the criteria for a listed impairment, particularly the paragraph C criteria of Listed Impairment 12.04. The court vacated the district court’s judgment and remanded the case to the agency for further proceedings, including a fuller consideration of the existing evidence and the results of a consultative examination.
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