Keyser v. Commissioner Social Security Administration

Pamela Keyser (plaintiff) suffered from severe emphysema, depression, anxiety, bipolar disorder, and schizotypal personality traits. Keyser had previously worked as a cashier in a role that required prolonged standing but was unable to continue working due to her physical and mental ailments. Keyser applied for social security disability (SSD) benefits based on her combined ailments. In Keyser’s application, her treating physicians reported that Keyser’s emphysema was severe enough to prevent her from working. Keyser’s psychiatrist, Dr. Monteverdi, assessed Keyser’s functionality as moderately impaired in a variety of areas impacting her ability to work. On behalf of the Social Security Administration, Dr. Lahman prepared a Psychiatric Review Technique Form (PRTF), which stated that Keyser suffered from mild functional impairments impacting her ability to conduct daily activities, maintain concentration, and maintain social functioning. At a hearing before an administrative-law judge (ALJ) regarding Keyser’s SSD application, a vocational expert testified that Keyser was unable to perform her prior cashier’s job, which required extended standing, but that she could perform a seated cashier’s job. The ALJ denied Keyser SSD benefits. In a written decision, the ALJ held that sedentary cashier positions were readily available and were within Keyser’s ability to perform. The ALJ failed to append a PRTF to the decision and failed to include specific findings regarding Keyser’s mental functionality. Keyser appealed the ALJ’s decision to the federal district court, which affirmed. Keyser then appealed to the Ninth Circuit.