Background
Pakita Wright appealed the district court’s affirmance of the Social Security Administration’s denial of her claims for disability insurance benefits and supplemental security income. She argued that the administrative law judge failed to properly consider her migraine headaches at step three of the sequential disability evaluation process and did not support her decision with substantial evidence regarding her subjective complaints.
The court’s reasoning
The court reviewed the administrative law judge’s decision de novo to determine if the correct legal standards were applied and if substantial evidence supported the denial. The court explained that while migraine headaches are not a listed impairment, they may medically equal epilepsy under Listing eleven point zero two B if they meet specific criteria regarding frequency, treatment adherence, and functional limitations. The court found the administrative law judge’s decision insufficient because it did not discuss Listing eleven point zero two B or Social Security Ruling nineteen point four P, nor did it analyze the specific factors required to determine medical equivalence, such as the duration, intensity, and side effects of treatment.
What it means going forward
The decision requires the Social Security Administration to re-evaluate the claimant’s migraine headaches using the specific analytical framework for medical equivalence to epilepsy, ensuring all relevant medical criteria are explicitly addressed in the administrative record.
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