New York District Court Remands
January 13, 2017. In this case, a claimant with severe mental impairments was denied benefits after the ALJ rejected the opinions of the claimant’s treating physicians in favor of non-acceptable medical sources, citing that the treating physicians submitted “fill in a blank” and “check the box” opinions and did not provide enough information. The district court disagreed with this reasoning, finding it “odd” as the Commissioner frequently utilized these form opinions for their own physicians and ALJs often relied upon them in denying benefits; it further held that if the ALJ was left with questions regarding these opinions, he had the “heightened duty” to further develop the record and find out more information, especially considering this was a case involving psychiatric impairments. The district court reversed the ALJ’s decision and remanded for further proceedings.