Garcia v. Comm’s of Soc. Sec.

Summarized by:

  • Court: 9th Circuit Court of Appeals Archives
  • Area(s) of Law: Administrative Law
  • Date Filed: 09-23-2014
  • Case #: 12-15686
  • Judge(s)/Court Below: Circuit Judge Murguia for the Court; Chief Judge Kozinski; Dissent by Circuit Judge O’Scannlain
  • Full Text Opinion

In order for there to be no legal error for determining that an individual is entitled to social security benefits, a complete record must be implemented.

Stephanie Garcia received social security benefits as a minor based on her intellectual disability. When she turned 18, she was reevaluated by the Social Security Administration, which determined that “she no longer qualified as disabled and was therefore not entitled to further benefits.” She appealed to an administrative law judge (“ALJ”) who affirmed the administration’s initial findings. During the hearing, Garcia continued to live with and rely on her mother for support. She also had a daughter who is disabled and also relied on Garcia's mother for care. After holding two different part time jobs, Garcia quit because she found the work to be too demanding and she required constant supervision from her coworkers. At the hearing, the ALJ relied on three different doctors who had conducted psychological evaluations on Garcia to determine if she was capable of employment. One of the doctors concluded that Garcia was capable of performing “light, unskilled jobs.” Based on this determination, and based on the fact that Garcia’s IQ fell within the “borderline range of disability,” the ALJ determined that Garcia was no longer eligible for benefits. However, during the hearing, the full range of disability tests were not conducted on Garcia. On appeal, the Ninth Circuit determined that “[i]t was legal error for the ALJ not to ensure that the record included a complete set of IQ test results that both the ALJ and the reviewing experts could consider.” To determine if an adult has a disability, a five-step process is implemented. However, in this case, two steps were skipped when the ALJ made her conclusion. Therefore, the panel determined that the ALJ’s failure to develop a complete report for review was a legal error that could possibly have affected the outcome of the case. REVERSED and REMANDED.

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