Bustamante v. Massanari

Joseph Bustamante (plaintiff) applied for disability benefits, claiming that a combination of his physical and mental impairments prevented him from working. Bustamante had diabetes and a history of successfully treated pulmonary tuberculosis. Bustamante’s mental impairments included a personality disorder and a 20-year history of substance-abuse-addiction disorder. Following a hearing, an administrative-law judge (ALJ) found that Bustamante’s physical impairments were not disabling because Bustamante’s diabetes was not severe and his pulmonary tuberculosis was managed with medication. The ALJ rejected Bustamante’s mental impairments, finding that his primary impairment was alcohol abuse, not an independently severe physical or mental impairment, and any of Bustamante’s impairments that might rise to the requisite level of severity were secondary to his alcoholism. The ALJ concluded that Bustamante retained the physical and mental ability to return to his past relevant work. The ALJ’s final conclusion was that alcohol abuse was a contributing factor material to the finding of disability. Therefore, the ALJ concluded at step two that Bustamante’s disability was a product and consequence of his alcohol abuse before deciding whether he was disabled according to the administration’s five-step sequential process. The ALJ’s decision became the final decision of the Commissioner of the Social Security Administration, Larry Massanari (defendant). Bustamante sought judicial review, and the commissioner’s decision was upheld. Bustamante appealed.