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Court Analyzes Relevance of Alcoholism in a Residual Functional Capacity Evaluation

In evaluating a person’s claim for Social Security Disability Insurance (SSDI) benefits, the Social Security Administration must engage in a multiple-step process to determine if a person is disabled, and if so, whether the person has a residual functional capacity to obtain gainful employment. Recently, the United States District Court for the District of Massachusetts analyzed whether evidence of alcoholism should be considered in evaluating a person’s residual functional capacity in a claim for SSDI benefits. If you are unable to work due to a disability, you should meet with a skilled Massachusetts social security disability attorney to discuss your eligibility for SSDI benefits.

Facts Regarding the Plaintiff’s Health

It is reported that the claimant had a history of chronic alcohol abuse. From 2009 through 2012, she presented to the emergency room on several occasions for treatment due to alcohol withdrawal and underwent in-patient alcohol treatment numerous times. During each visit to the hospital and admission for alcohol treatment, the claimant’s mood and mental status were assessed, and it was routinely noted that she suffered from varying degrees of anxiety.

Allegedly, the claimant began treating with a psychiatrist in 2015, and was diagnosed with anxiety and depression. In October 2015, the claimant filed an application for SSDI benefits, alleging that she was unable to work since May 2008 due to her anxiety and depression. Her claim was denied, and she exhausted her administrative remedies. Thus, the claimant’s appeal was heard by the district court.

Evaluation of Residual Functional Capacity

In evaluating whether a person is disabled and therefore entitled to SSDI benefits, an administrative law judge will engage in a multiple step process. The first three steps require a determination as to whether the claimant suffers from a severe impairment. If so, the judge must then determine if the claimant has a residual functional capacity that allows the claimant to perform past relevant work. If the claimant cannot perform past relevant work, the judge then assesses whether the claimant is capable of performing other work. It is only if the judge finds that a claimant is unable to perform any work that he or she will be deemed disabled.

In the subject case, the administrative law judge found that while the claimant suffered from severe impairment due to her anxiety and was unable to perform her past relevant work, she could nonetheless perform other work and therefore was not disabled. The claimant argued that the judge erred in failing to consider that she was self-medicating her underlying mental illness with alcohol when evaluating her residual functional capacity. The court disagreed, noting that alcoholism, in and of itself, was insufficient to show that the evaluation of the claimant’s residual functional capacity was not supported by the evidence. Thus, the court affirmed the administrative law judge’s ruling.

Meet with a Seasoned Massachusetts Social Security Disability Attorney Regarding Your Case

If you cannot work because of a mental or physical disability you should meet with a seasoned Massachusetts Social Security Disability attorney to discuss whether you should file a claim for Social Security Disability Insurance benefits. The experienced social security attorneys of Karsner & Meehan will work diligently to present effective arguments in support of your claim. We can be reached at 508-822-6600 or through the online form to schedule a meeting to discuss your case.