Schaal v. Callahan

Daniel J. Schaal (plaintiff) applied for Social Security disability insurance benefits based on his schizoaffective disorder. To support the application, Schaal submitted a personal-data questionnaire indicating that he had no trouble sleeping, functioning, or caring for himself; he shopped for his own food; he completed a few household chores; and he was mobile via public transportation. Schaal’s parents, whom he lived with, also submitted responses to questionnaires, which differed, with Schaal’s father indicating that Schaal spent most of his time alone, seldomly completed tasks unassisted, did not care for himself consistently, without coaxing, and occasionally experienced sleeplessness. In a hearing before an administrative-law judge (ALJ), a social worker, whom Schaal reported to for volunteer work and monthly counseling sessions, testified that Schaal was unable to perform regular, continuous work in a competitive setting because he lacked sufficient concentration, could not follow complicated instructions nor make immediate decisions, required constant supervision to complete tasks, and frequently exhibited anxiety-related behavior. The ALJ found that Schaal’s mental impairment was severe but concluded that Schaal was not disabled because his functional limitations were not severe enough to meet the administration’s listing for schizoaffective disorder. This conclusion was based on findings that Schaal had no restrictions in his daily activities; slight difficulty in social functioning; few deficiencies in concentration, persistence, or pace, causing untimely completion of tasks; and no episodes of deterioration or decomposition in work settings, causing him to withdraw or exacerbating his condition. The ALJ’s decision did not account for any of the questionnaires and made brief mention of the social worker’s testimony; it was the final administrative decision. Schaal sought judicial review.