WDNY — Non-Exertional Limitations: Crayton v. Astrue

U.S. District Court, WDNY

Non-Exertional Limitations

Mental Impairments

Crayton v. Astrue
11-cv-6617L
Judge Larimer

Background: The plaintiff appealed from the denial of her application for Supplemental Security Income benefits. The plaintiff alleged that she had an inability to work due to depression, arthritis, scoliosis, anxiety and asthma. The administrative law judge found the claimant not disabled under the Social Security Act.  Both parties have cross-moved for summary judgment.

Ruling: The District Court granted the plaintiff’s motion for summary judgment. The court found that the ALJ failed to apply the correct legal standards in analyzing the plaintiff’s non-exertional limitations. Specifically, the plaintiff’s medical records consistently indicated the presence of one or more medically determinable mental impairments. However, the ALJ failed to apply a psychiatric review technique form in determining the effect these mental impairments had on the plaintiff.

Jaya Ann Shurtliff and Kenneth R. Hiller of the Law Offices of Kenneth Hiller for the plaintiff; Kathryn L. Smith of the U.S. Attorney’s Office for the defendant