Easterbrook v. Kijakazi, No. 21-2193 (4th Cir. 2023)
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In this case heard before the United States Court of Appeals for the Fourth Circuit, the plaintiff, Daniella Easterbrook, appealed the denial of her application for disability benefits by the Social Security Administration. Easterbrook, who has suffered from persistent back pain since 2011, argued that the Administrative Law Judge (ALJ) failed to provide a "good reason," supported by substantial evidence, for not giving adequate weight to the opinions of her treating physician, Dr. John Kim.
The court agreed with Easterbrook, stating that the ALJ erred in not applying the "treating source rule" to Dr. Kim's opinions and not providing a sufficient justification for giving his opinions less weight. The court noted that Dr. Kim's opinions were well-supported by medically acceptable clinical and laboratory diagnostic techniques and were consistent with the substantial evidence in the record.
The court also found that the ALJ's reasons for discounting Dr. Kim's opinions, such as Easterbrook's decision not to undergo certain treatments, were inappropriate and did not constitute "good reasons." The court stated that a patient's refusal to pursue a specific type of medical treatment does not automatically call into question the severity of her pain.
As a result, the court reversed the Commissioner's decision and remanded the case for a determination consistent with its opinion.
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