Williams v. Colvin

Record failed to contain sufficient evidence to support ALJ’s finding that claimant seeking social security disability benefits was totally disabled as of November 2008, as opposed to earlier date due to variety of physical and psychological ailments. Although ALJ found that neither physical nor psychological ailments were disabling when considered in isolation, ALJ should have considered possibility that combination of all of said ailments could have rendered claimant disabled at earlier date. ALJ also failed to consider whether claimant’s edema, chronic pain or severe headaches rendered claimant disabled, and ALJ should have sua sponte questioned claimant as to nature and extent of her condition, even though claimant’s counsel did not want her to testify.