Moran v. Astrue
United States Court of Appeals for the Second Circuit
569 F.3d 108 (2009)
- Written by Samantha Arena, JD
Facts
James Moran (plaintiff) was a disabled individual diagnosed with anxiety, depression, arthritis, and other conditions. Moran applied for Social Security benefits several times. Moran’s first three applications were denied. After two courts determined in separate cases that Michael Astrue, the Commissioner of the Social Security Administration (SSA) (defendant), misapplied the disability regulations in evaluating applications, affected applicants were entitled to request reconsideration of the applicants’ application denials. Moran requested reconsideration of his 1980 and 1987 applications. The SSA denied reconsideration. Moran sought a hearing before an administrative-law judge (ALJ) to contest the denial. Moran appeared pro se at a hearing lasting only 24 minutes. The ALJ questioned Moran and his wife, resulting in a hearing transcript less than 13 pages long. After reviewing pay stubs from Moran’s work at an orchard, the ALJ found that Moran had performed “substantial gainful activity” in 1985 and 1989, disqualifying Moran from receiving benefits. On this basis, the ALJ affirmed the SSA’s decisions to affirm the denials of Moran’s applications. Moran appealed.
Rule of Law
Issue
Holding and Reasoning (Sack, J.)
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