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Chaney v. Colvin: Residual Functioning Capacity (RFC) in Disability Cases

Chaney v. Colvin, a case from the United States Court of Appeals for the Eighth Circuit, involves a claimant who filed for disability benefits in 2006 for a disability that he asserted began in 2003. Claimant testified during a hearing held by an administrative law judge (ALJ) who works for the United States Social Security Administration (SSA).

1028452_syringes_and_vialDuring his testimony, claimant stated he had long suffered from back pain, depression, and was addicted to drugs. He also testified that he had full physical custody of his daughter, then four years old, but was given considerable help from his parents. His parents regularly cleaned his home, paid his rent and utilities and provided him with other needed assistance.  

Following a review of the evidence submitted during the hearing process, ALJ made a determination that claimant had engaged in substantial gainful activity (worked) in 2003. However, he had not done so since that time. It was in 2003 that claimant graduated from massage school.

The ALJ determined claimant suffered from chronic lower back pain, was overweight, had high blood pressure, borderline liver disease, cholesterol issues, and spinal disc issues. However, he found that even with all of these different impairments, no single one of these conditions or any combination of them qualified him as disabled under the rules and regulations for government SSA hearings and adjudication. He therefore declared ALJ was capable of working under his current residual functioning capacity and was not entitled to collect Social Security Disability Insurance (SSDI) benefits.

At this point, claimant filed an appeal with the Appeals Council, but the council refused to hear the appeal. The SSA is a federal agency with offices across the nation to handle appeals at the ALJ level. After an ALJ makes a finding, claimants can file an appeal with the agency’s Appeals Council. However, there is not an absolute right to appeal, and the board can decide to decline review of a case. This does not mean claimant is out of options, as the claimant can appeal the case to the United States District Court for the district in which in which claimant resides.

For example, if claimant wished to appeal a Social Security disability case in Boston, he or she could file an appeal with the United States District Court for the District of Massachusetts located on Fan Pier in Boston.   If the United States District Court affirms SSA’s denial of benefits, the claimant can then file what is essentially his or her final appeal to the United States Court of Appeals for the First Circuit. As it so happens, the United States Court of Appeals for the First Circuit is located in the same building as the Massachusetts District Court, which is the John Joseph Moakley Federal Courthouse.

In Chaney, the United States District Court affirmed the lower ALJ’s finding on grounds that it was accurately supported by credible evidence, so claimant then appealed to the United States Court of Appeals for the Eighth Circuit. In this appeal, the court agreed with the decisions of the lower courts and affirmed ALJ’s ruling.

If you are seeking Social Security Disability Insurance benefits in Boston, call for a free and confidential appointment at 1-888-367-2900.

Additional Resources:

Chaney v. Colvin, February 2, 2016, United States Court of Appeals for the Eighth Circuit

More Blog Entries:
Hanson v. Colvin: A Critical Look by a Court of Appeals on a Denial of Benefits, August 14, 2014, Boston Disability Lawyers Blog.