Schink v. Commissioner of Social Security
Case Number : 17-14992 Date Filed : 08/27/2019
Tags : Bipolar Disorder, Mental Disabilities, Social Security Disability, SSDI, Disability Claim, Disability Appeal, 11th Circuit Court of Appeals, Alabama, Florida, Georgia
Key Takeaways : Bipolar disorder recognized as a mental disability for purpose of disability benefits based on severity; significant impairments with the ability to interact with others can impede and individuals ability to work; significant weight should be given to medical professionals treating SSDI applicants unless proof is shown otherwise.
Relevant Links : Schink v. Commissioner of Social Security
Case Summary
The 11th Circuit Court of Appeals heard a case in which an applicant for Social Security Disability Insurance (SSDI) had his application denied by the Social Security Administration (SSA). His application was then denied on Reconsideration of his application. The applicant's appeal before the Administrative Law Judge (ALJ) was also denied. The Appeals Council affirmed the ALJ’s decision and the applicant appealed the decision to the District Court, which affirmed the Appeals Council’s decision.
On appeal before the 11th Circuit Court of Appeals, the applicant argued that the ALJ incorrectly denied his claim for benefits in spite of considerable testimony from experts. At issue was the applicant’s history of bipolar disorder which was a significant part of his claim for SSDI benefits. Before the case came to the Circuit Court, it had gone back and forth on appeal between the ALJ and the Appeals Council. The applicant's claim that the Appeals Council should not have sent the case back to the ALJ because he was already biased on the basis of his prior decision, was dismissed.
The applicant had presented detailed medical evidence of his bipolar condition and how it affected his ability to work to the SSA and the ALJ. This included documentation from numerous mental health professionals of his history of bipolar disorder. Along with the documentation were questionnaires filled out by two mental health professionals who had treated the applicant for his condition. They noted extreme or marked ability to behave in a predictable, reliable, and emotionally stable manner. In addition evidence was presented regarding the medications that had been prescribed for him over several years, a family history of depression, and a week-long hospital stay for bipolar disorder and severe depression. The ALJ found that the applicant did not have a severe enough mental impairment to qualify for disability insurance and deemed him fit to work.
The 11th Circuit Court found that the ALJ did not provide any adequate reason why it gave minimal weight to the testimony from the two mental health professionals who treated the applicant and filled out the questionnaires regarding his condition. Additionally, the 11th Circuit Court compared the extensive evidence provided by mental health professionals regarding the applicant’s condition to the ALJ’s reliance on two mental health professionals who evaluated the applicant on behalf of the state SSA, one of whom had only met with him once and the other had never met with him at all. The Ciruit Court additionally found that the ALJ only relied on the applicant's physical ability to work and did not properly consider the degree to which his mental disability impeded his ability to work. The Circuit Court rejected the ALJ’s assessment that the applicant was able to participate in normal activities of daily living pointing out that the activities in question were solitary acts such as shopping and caring for pets. According to the Circuit Court, the ALJ did not properly consider that the applicant’s bipolar disorder caused significant impairments with his ability to interact with others.
The 11th Circuit Court overruled the District Court's decision and sent the case back to the District Court for a proceedings consistent with the Circuit Court's findings. The Circuit Court’s decision indicates that the findings of medical and mental health officials treating an individual who applies for disability benefits should be given significant weight unless proof to the contrary is otherwise shown. The Circuit Court’s finding also indicates that the courts may be gaining a better understanding of the condition of bipolar disorder and the degree that it, and other mental disabilities, can impair an individual's ability to work. The 11th Circuit Court covers the Federal Districts in Alabama, Georgia, and Florida.