Taylor v. Comm. of Soc. Sec. Admin.

Further proceedings to determine the award of disability insurance benefits are in order when the Administrative Law Judge and Appeals Council do not fully consider all submitted, relevant medical evidence and testimony favorable to the claimant’s alleged disability.

In 2006, Steven Taylor applied for disability insurance benefits under the Social Security Act. After Taylor’s application was denied by the Administrative Law Judge (ALJ), he “submitted a request for review” to the Appeals Council (Council). Taylor submitted new medical evidence to the Council as part of his request, including a “psychiatric evaluation” and “medical source statement” pertaining to the onset of his alleged disabilities prior to the expiration of his disability insurance coverage in 2004. The Council denied Taylor’s request and did not consider the “psychiatric evaluation” or “medical source statement.” The Council further found that the rest of the newly submitted medical evidence was irrelevant because it was created after 2004 and therefore did not bear on the issue of whether Taylor “was disabled at the time he was last insured.” The district court affirmed the Commissioner’s decision to deny Taylor benefits. Taylor requests that the Ninth Circuit find the newly submitted medical evidence to be accurate and, as such, that the Court remand his case to the district court with instructions to grant benefits. The Court reversed the district court and remanded to the ALJ for further proceedings. The Court held that the ALJ and Council had made several errors in order to make a fully informed determination on disability benefits, including overlooking the “psychiatric evaluation” and “medical source statement” and disregarding medical evidence and testimony helpful to Taylor’s case. REVERSED and REMANDED.