Unreported / Non-Citable
Background
L.M. challenged a partially favorable Social Security disability ruling that recognized disability only beginning in October 2020. The central dispute was not whether later disability existed, but when a slowly progressive combination of impairments became disabling. The administrative law judge rejected the medical assessments covering the earlier period and independently translated raw treatment records into a sedentary-work capacity.
The Court’s Holding
The court reversed in part and remanded. Although an administrative law judge may evaluate medical evidence, the judge cannot reject every functional assessment for the disputed period and then construct detailed work limitations from raw clinical findings without adequate medical support. Because determining the onset of a progressive disability is medically dependent, further development—including medical-expert assistance where appropriate—was required.
Key Takeaways
- ALJ must obtain a medical basis before fixing an onset date after rejecting every contemporaneous functional assessment.
- The ruling turns on the governing legal standard and the specific evidentiary record, not labels alone.
- Practitioners should preserve a clear, fact-linked record for review and remedy.
Why It Matters
For disability practitioners, the decision distinguishes permissible evaluation of competing opinions from an ALJ effectively acting as a medical expert. When onset is the decisive issue, counsel should identify the evidence tying clinical findings to work functions and press for record development rather than allowing an unsupported residual-functional-capacity finding.