We often see clients in Social Security Disability cases who are unable to work due not only because of one physical or mental impairment, but due to a combination of impairments which, together, can wreak havoc on a person’s everyday life. In Bryant v. Astrue, the District Court for the District of New Jersey explained that, when considering a claim by a person who suffers from severe obesity, the government must not only determine the effect of the obesity alone, but also its effect on any other impairments.
The Social Security Administration (SSA) rejected Plaintiff Lorraine Bryant’s disability benefits claim where she asserted that she was unable to work due to asthma, glaucoma, hypertension, obesity, depression and a history of substance abuse. Plaintiff then appeared before an SSA Administrative Law Judge (ALJ) in an administrative hearing in New Jersey. Following the hearing, the ALJ determined that Bryant was not disabled for benefits purposes because, although she could not return to her previous job as a sales representative, she could nevertheless transition to other available jobs in the New York-New Jersey-Connecticut area.
On appeal, the District Court remanded the case to the ALJ, finding that the judge failed to assess the impact of Plaintiff’s obesity on her other impairments. Citing the Third Circuit’s 2009 decision in Diaz v. Commissioner of Social Security, the Court ruled that an ALJ considering a disability benefits claim by a person who suffers from obesity must perform an “individualized inquiry” that “focus[es] on the combined effect of obesity and other severe impairments.” Specifically, “an ALJ must meaningfully consider the effect of a claimant’s obesity, individually and in combination with her impairments,” the Court held. That includes discussing the relevant evidence and explaining the weight afforded it in a manner that allows a reviewing court to perform its duty.
In this case, the ALJ determined that Plaintiff suffered from severe obesity and indicated that he considered its impact on her ability to work. The judge did not, however, explain what analysis was performed, nor set forth the reasons for concluding that Plaintiff could continue to work despite her obesity and other impairments. Thus, the Court remanded the case “for further analysis as to the impact of Plaintiff’s obesity on her other impairments.”
Until 1999 a person who suffered from obesity could have been found eligible for Social Security Disability benefits if he or she was unable to work for a year. At that point obesity was removed as a a disabling impairment in and of itself, but in a Ruling that is binding on the ALJ’s, Social Security pointed out that the impact of obesity on all other impairments that a claimant has must be considered.
As the Court made clear in its ruling, obesity is a serious condition that can have a debilitating effect on those who suffer from it. It can result in a number of other impairments and exacerbate existing impairments. The ALJ cannot simply give this direction lip service. He must truly analyze the impact that obesity has on a claimant’s other conditions.
