WEIGHT OF MEDICAL EVIDENCE
Coleman v. Astrue, 498 F.3d 767
In this Social Security Disability case the plaintiff had a severe allergy. The district court erred in failing to remand the case for clarification of the medical opinions. The Administrative Law Judge should have contacted the treating specialist because his report did not contain all the necessary information. He found that the plaintiff could perform sedentary work, with some restrictions. Whether a claimant can work sedentary work is a question for a vocational expert, not a medical source. Further the residual functional capacity listing the restrictions was not in the record, so the court cannot know what restrictions the treating specialist intended. Further the Administrative Law Judge discounted the state agency doctor's opinion because it conflicted with the treating physician's opinion. The court could not determine if this was accurate, because the treating physician's records were incomplete. The Administrative Law Judge also improperly relied on the opinion of the consulting non-examining physician who did not address the plaintiff's latex allergy. The medical record also contained a statement that the plaintiff should be very careful in regard to her latex allergy and employment. The Administrative Law Judge should have contacted this again doctor for clarification of his opinion regarding the plaintiff's need for a latex free environment.
In this
Social Security Disability case, the decision denying benefits was reversed and the case was remanded.