Background
Kyle D. sought review of a Social Security decision denying disability benefits after serious injuries from being struck by a vehicle. The administrative law judge found he could perform a range of light work and omitted any need for a cane from the residual functional capacity assessment.
The ALJ reasoned that emergency-room records did not document cane use and discounted a medical opinion supporting greater limitations. Other records, function reports, physical-therapy notes, and testimony repeatedly documented an assistive device and abnormal gait.
The Court’s Holding
The court reversed because the ALJ’s factual premise was wrong: an emergency-room record expressly said Kyle walked with a cane. The broader record also substantially corroborated cane use, so the omission was not supported by substantial evidence and the medical opinion had not been properly evaluated.
The error mattered because the vocational expert testified that needing a cane would compromise bilateral manual dexterity and preclude the identified jobs. The court remanded for further administrative proceedings rather than ordering benefits because factual issues remained for the agency.
Key Takeaways
- An ALJ cannot rely on an asserted evidentiary gap that the record directly contradicts.
- Residual functional capacity must reflect material assistive-device evidence.
- Vocational testimony can establish prejudice when an omitted limitation eliminates available work.
- Even harmful error may lead to further proceedings rather than immediate benefits.
Why It Matters
The decision is useful for disability advocates confronting selective readings of medical records. Practitioners should connect each functional limitation to specific treatment notes and vocational testimony, making both the agency error and its effect on the jobs analysis unmistakable.
Read the full opinion (PDF) · Court docket