Jones v. Commissioner of Social Security.

On November 6, 2023, the Eleventh Circuit affirmed the ALJ’s decision in Jones v. Commissioner of Social Security. Let’s dive in…

Jones appealed the denial of her supplemental security claim, arguing that the ALJ hadn't properly evaluated her Rheumatoid Arthritis under Listing 14.09. Now, this is where the details get interesting—Listing 14.09A requires a pretty high bar, including the inability to ambulate effectively without certain assistive devices such as a cane, crutch, or walker. The ALJ found that Jones didn't meet this requirement.

Then there's Listing 14.09B, focusing on inflammation in major joints and the involvement of other body systems. The ALJ found that Jones fell short here too, lacking evidence to prove involvement of multiple body systems or meeting the necessary criteria.

The Eleventh Circuit agreed that Jones did not meet her burden for 14.09. First, the Court found that Jones did not qualify under Listing 14.09A “because Jones did not demonstrate that she needed to use a hand-held assistive device that limited the functioning of both of her upper extremities.” Second, Jones did not qualify under Listing 14.09B “because she has not provided any citations to law or authority or evidence that her depression and anxiety involved the central nervous system… [and] she did not demonstrate that she had a sufficient impairment from any of her cardiovascular symptoms; her medical records relating to her chest pain repeatedly did not reveal cardiological disease, and the ALJ did not find that her chest pain, tachycardia, or venous insufficiency were sufficient impairments.”

This case underscores that Listings are hard. Listing 14.09 has specific, stringent requirements that must be present. Being meticulous in presenting that evidence can strengthen a claim significantly.

But the Decision doesn’t end there. It continues with a discussion about Jones’ statements. The Court found that “substantial evidence in the record demonstrates that the ALJ considered all of Jones’s alleged impairments and subjective complaints of pain when she determined that Jones had an RFC to perform light work.”

This case also underscores the necessity of consistency between a claimant's statements and the medical evidence. It is important to make sure that a client's testimony aligns closely with the documented medical records, and if it doesn’t, then there should be a discussion as to why at the hearing. Any discrepancies might sway the decision against the claimant, so addressing this head-on can help clear up the issue.

Got any questions? Schedule a consultation with us. I’m here to help. It’s a lot to take in, but we’ll get through it together. After all, navigating these waters is always easier when you’ve got someone to chat with.