Alban v. Astrue
A decision of an administrative law judge that is not buttressed by substantial evidence in the record can be reversed. In October 2008, the plaintiff, Eunice Alban, applied for Social Security disability benefits, alleging that she suffered from arthritis, a spinal disorder, asthma, migraines and hip problems. Administrative Law Judge Eileen Burlison found that the plaintiff failed to establish she was disabled. In 2012, Magistrate Judge Joan Margolis found extensive evidence existed that the plaintiff suffered from a severe cervical spine disorder. Magistrate Margolis recommended that the plaintiff receive benefits, because the administrative law judge wrongly concluded the plaintiff's spine disorder did not meet or equal a listed impairment. The District Court found that Judge Margolis correctly found that the plaintiff suffers from a listed disability of the spine and qualifies as per se disabled. "[T]he ALJ's stark conclusion," wrote the court, "actually contravenes the wealth of detailed evidence of spinal disorder that Plaintiff presented." The record established that the plaintiff suffered neuroanatomic distribution of pain, sensory loss, restricted motion of the spine and muscle weakness. "[M]edical evidence in the record," wrote the District Court, "clearly establishes that Plaintiff's impairment meets or equals a `disorder of the spine.' " The plaintiff proved that she was disabled and entitled to benefits retroactive to October 2008.