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2 min read

When Substance Abuse and Disability Intersect: Assessing Alcoholism in Disability Determinations

a bottle and a glass of alcohol in the foreground, and a person with their hands on their face in an expression of despair in the background

In the appeals case of Stephen E. Brueggemann challenging the denial of social security disability benefits, Brueggemann argued that the administrative law judge overseeing the claim did not follow the correct procedure when evaluating claims related to alcoholism. Consequently, the Court of Appeals intervened to thoroughly assess the validity of Brueggemann's appeal through a de novo process, entailing a comprehensive re-examination of the evidence and legal arguments.

The Burden of Proof: Establishing Alcoholism's Impact on Disability

When it comes to evaluating Social Security Disability cases related to alcoholism and substance abuse, the proper procedure is critical in ensuring fair and accurate determinations. The recent appeals case of Stephen E. Brueggemann serves as a prime example of the importance of following the correct procedure when assessing claims involving alcoholism.

A crucial aspect of these claims is the burden of proof, specifically establishing whether alcoholism is a contributing factor to disability. In these cases, the burden falls on the claimant to prove that alcoholism is not a significant factor in their disability. If the administrative law judge overseeing the case cannot definitively determine the extent to which a substance use disorder contributes to the disability, the claimant's burden is considered met, warranting the granting of disability benefits.

In the case of Stephen E. Brueggemann, significant concerns were raised about the administrative law judge's handling of the claim. The judge dismissed crucial evidence from Brueggemann's treating physician that suggested his disability was unrelated to alcohol abuse. The evidence presented in Brueggemann's favor included reports and notes from Dr. Partap, his treating physician, as well as an evaluation of medical evidence from Dr. Shuman, the Commissioner's chosen examiner. A comprehensive review of this evidence revealed Brueggemann's struggles with severe mental illnesses, including depression, anxiety, and paranoid schizophrenia. These documented conditions, combined with his challenges with alcohol addiction, painted a clear picture of an individual facing significant hurdles in their daily life.

The Court of Appeals recognized the failure of the administrative law judge to adhere to proper procedure in handling claims related to alcoholism. Specifically, the judge's decision that disability cannot be based on drug and alcohol use significantly undermined the opinion of Brueggemann's treating psychiatrist and raised doubts about the credibility and accuracy of the final ruling. The Court highlighted the multiple indicators of reliability found within the evidence, such as reports and notes from Dr. Partap and Brueggemann's own testimony, which vividly described the debilitating symptoms he experienced. Additionally, instances where Brueggemann required hospitalization during periods of sobriety further underscored the severity and impact of his condition.

Court of Appeals' Decision to Reverse and Remand the Case

In light of the flaws in the administrative law judge's approach, the Court of Appeals made the decision to reverse and remand the case to the district court. The district court was instructed to conduct further administrative proceedings in line with the findings and opinions of the Court of Appeals. This ruling breathed new life into Brueggemann's pursuit of SSDI benefits and ensured that his claim would be more thoroughly evaluated, considering all the evidence and adhering to proper procedure.

This case highlights the importance of following the correct procedure when evaluating Social Security Disability claims related to alcoholism. It emphasizes the need for a comprehensive examination of all medical evidence, including evidence from treating physicians and independent evaluations, to ensure a fair and accurate determination of disability. By upholding proper procedure, the Social Security Administration can better serve individuals like Stephen E. Brueggemann, ensuring that their claims are given the attention and consideration they deserve.

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