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Stieberger v. Bowen
United States Court of Appeals for the Second Circuit
801 F.2d 29 (1986)
In an earlier case, the United States Court of Appeals for the Second Circuit held that the opinion of a disability-benefits applicant’s treating physician was binding on the Social Security Administration (SSA) (defendant) unless substantial evidence contradicted the opinion (the treating-physician rule). The SSA refused to follow the Second Circuit’s holding, instead adopting internal guidelines that explained the SSA would give increased weight to a treating physician’s opinion. The internal guidelines did not state that the treating physician’s opinion would be binding on the SSA unless it was contradicted by substantial evidence. In several cases, the SSA denied benefits to applicants after disregarding the opinion of the applicant’s treating physician. The United States District Court for the Southern District of New York issued a preliminary injunction against the SSA that barred the SSA from denying or terminating disability benefits in a way that went against a decision of the Second Circuit. The SSA was also required to revoke all internal guidelines that went against a decision of the Second Circuit and was further required to notify all employees of the Second Circuit’s precedents regarding the treating-physician rule. After the district court issued the injunction, the Second Circuit held in another case that the SSA was required to draft instructions to its adjudicators about how to apply the treating-physician rule and to explain that the treating-physician rule was mandatory. The SSA challenged the district court’s preliminary injunction.
Rule of Law
Holding and Reasoning (Newman, J.)
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