Employee Benefits

Record failed to contain sufficient evidence to support ALJ’s denial of claimant’s application for Social Security disability insurance and SSI based on claimant’s back condition, even though ALJ found that claimant’s statements about nature and extent of her pain symptoms were not credible. Remand was required where: (1) ALJ did not inquire more deeply about claimant’s limited treatment history that, according to ALJ, failed to provide quantifiable test results to support her claims of back pain; and (2) ALJ misstated record regarding number of hours and amount of weight that claimant could work/lift during typical day. Moreover, claimants account of her pain was not so contradicted by medical evidence so as to be incredible.

Dist. Ct. did not err in finding that two corporations that were established contemporaneously with debtor corporation’s closing were subject to successor liability under ERISA for purposes of payment of past due pension fund debt incurred by debtor corporation, where said corporations were substituted for debtor corporation under Rule 25(c) motion that was granted without hearing. Record showed that: (1) owner of substituted corporations was also official in debtor corporation and had notice of instant pension fund debt; (2) one substituted corporation hired five of six former employees of debtor corporation; (3) all three corporations operated out of owner’s home; and (4) there was continuity of business operations, where substituted corporations provided essentially same services to customers of debtor corporation. Fact that Dist. Ct. did not conduct evidentiary hearing prior to granting Rule 25(c) motion did not require different result.

Record failed to support ALJ’s denial of claimant’s application for Social Security disability benefits based on claimant’s cirrhosis of liver, low platelet count, hepatitis C and umbilical hernia conditions, where two doctors, including one employed by Social Security Administration, agreed that claimant could not engage in any gainful activity, and record otherwise showed that claimant’s medical conditions were so severe that he could not receive medical treatment to improve his condition. Fact that claimant’s employer at time claimant ceased to work would have allowed claimant to take two or three days off per week because of claimant’s ailments did not require different result where said employer made offer only because of claimant’s specialized expertise. Ct. further noted that ALJ committed series of factual errors when denying instant application.

Record supported ALJ’s finding that August 1991 was onset date of claimant’s claim of total disability on account of his pneumoconiosis. While Bd. found that benefits should have begun in June of 1999, when claimant filed his application, because there was no medical opinion evidence that reflected date upon which claimant had become totally disabled on account of pneumoconiosis, Ct. of Appeals found that onset of disease was August of 1991, where claimant stopped working due to breathing problems at that time, and where claimant’s 1991 pulmonary function tests qualified him for finding of total disability under applicable regulations. Moreover, defendant-employer failed to present any evidence indicating that claimant’s lung disease in 1991 was caused by something other than combination of coal dust and smoking.

Record failed to support ALJ’s denial of claimant’s application for SSI benefits based on claim that she suffered from cervical radiculopathy and psychological conditions that made it difficult for her to sustain employment. While ALJ could properly find that claimant was not credible with respect to her complaints of pain associated with her physical ailments, remand was required because ALJ improperly discredited claimant’s testimony concerning limitations caused by her bi-polar condition and failed to give physician’s opinion with respect to claimant’s mental condition appropriate weight it deserved under treating physician rule.

Dist. Ct. erred in granting defendant-pension plan’s motion for summary judgment in plaintiff-coal minor’s ERISA action alleging that defendant wrongfully denied his application for disability benefits under said plan, after defendant found that there was no causal link between plaintiff’s mine injuries and plaintiff’s award of Social Security disability benefits that, according to defendant, were based on physical and mental conditions that arose from car accident that occurred after plaintiff had left mine. Defendant, in denying instant application, failed to assess whether plaintiff’s mine injuries were “a causal link” in Social Security’s ALJ decision to award Social Security disability benefits, and record showed that plaintiff’s elbow injury from mine could have comprised “a causal link” in ALJ decision. Fact that elbow injury was not itself disabling did not preclude plaintiff from obtaining benefits under plan.