Workers' Compensation: Medical Reports Matter: Court Remands Disability Case

The U.S. District Court recently vacated and remanded a decision by the Commissioner of Social Security, emphasizing the critical importance of considering all relevant medical evidence, particularly reports generated within the context of a workers' compensation claim.

The case, A.D. v. Commissioner of Social Security, highlights the court's analysis regarding an Administrative Law Judge's (ALJ) failure to account for medical opinions from treating and examining physicians that were part of the claimant's workers' compensation file.

Court's Analysis on Overlooked Evidence
The court found that the ALJ erred by not considering or even mentioning relevant medical evidence from several doctors, including those whose reports stemmed from the plaintiff's disputed workers' compensation claim. The Commissioner argued that some of these reports were irrelevant because they were generated after the date the plaintiff was last insured or were not "treatment evidence" but rather opinions for workers' compensation purposes.

Impact on the Decision
The ALJ's failure to consider the medical reports from the workers' compensation claim directly impacted the court's decision. The court found that the ALJ's determination of the plaintiff's residual functional capacity did not comport with the law because not all evidence was considered. This oversight constituted reversible error, leading the court to vacate the Commissioner's decision and remand the case for further proceedings where the ALJ must properly consider all relevant medical evidence.

Key Takeaways To Consider

All Relevant Evidence: ALJs must consider all relevant medical evidence in the record, including reports and opinions generated for purposes other than treatment, such as workers' compensation claims.
Explain Evidentiary Rulings: If an ALJ chooses to discount or reject relevant medical evidence, they must provide a clear explanation for doing so.
Timing of Reports: Medical reports dated after the date last insured can still be relevant if they shed light on the claimant's condition during the insured period.
Workers' Compensation Reports are Relevant: Medical reports from workers' compensation cases are considered relevant medical evidence in Social Security disability determinations and cannot be overlooked.

A.D. v. Commissioner of Social Security, USDC NJ Civil Action No. 24-6321 (SRC), 2025 WL 1248933, Signed: April 30, 2025.

Not Approved for Publication

Recommended Citation: Gelman, Jon, Medical Reports Matter: Court Remands Disability Case, www.gelmans.com (05/07/2025) https://workers-compensation.blogspot.com/2025/05/medical-reports-matter-court-remands.html

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ORDER NOW

*Jon L. Gelman of Wayne, NJ, is the author of NJ Workers' Compensation Law (West-Thomson-Reuters) and co-author of the national treatise Modern Workers' Compensation Law (West-Thomson-Reuters). For over five decades, the Law Offices of Jon Gelman 1.973.696.7900
jon@gelmans.com has represented injured workers and their families who have suffered occupational illnesses and diseases.