## Facts

- Carl R. Boatner applied for Social Security disability benefits, alleging disability based on multiple physical and mental conditions.
- Boatner’s documented diagnoses included coronary-artery disease, two liver diseases, diabetes, obesity, spine disorders, high blood pressure, anxiety disorder, and major depressive disorder.
- In 2015, Boatner was diagnosed with chronic obstructive pulmonary disease (COPD) and spent months in hospice care.
- Treating physicians repeatedly described Boatner as chronically ill and disabled.
- Boatner was prescribed about 15 medications, each with potential side effects that could affect functioning (such as sedation, dizziness, and cognitive effects).
- Boatner filed for benefits multiple times and was denied; the repeated denials worsened his depression.
- An Administrative Law Judge (ALJ) found Boatner not disabled, concluding that none of his impairments met or equaled a listed impairment and that he retained residual functional capacity (RFC) to perform work.
- In reaching that result, the ALJ failed to address significant medical notes describing spinal problems, ministrokes, and respiratory limitations, and the ALJ repeatedly misread or misstated medical evidence.
- The Appeals Council denied review, making the ALJ’s decision the Commissioner’s final decision.
- Boatner sought judicial review in federal district court under 42 U.S.C. § 405(g).

## Issues

1. Whether the Commissioner’s final decision denying benefits was supported by substantial evidence and made using the proper legal standards under 42 U.S.C. § 405(g).
2. Whether the ALJ committed reversible error by ignoring or misinterpreting material medical evidence and by failing to evaluate the functional impact of side effects from Boatner’s many prescribed medications when determining RFC.

## Decision

- The district court reversed the Commissioner’s decision.
- The court concluded the ALJ’s analysis was not supported by substantial evidence because the ALJ ignored or misstated significant portions of the medical record, including records reflecting spinal issues, ministrokes, and respiratory problems.
- The court also found error in the ALJ’s failure to address the potential work-related limits caused by side effects of Boatner’s approximately 15 medications.
- The court remanded the case to the Social Security Administration for further proceedings consistent with the opinion, rather than ordering an immediate award of benefits.

## Legal Principles

- Under 42 U.S.C. § 405(g), a court reviews whether the ALJ applied the correct legal standards and whether the decision is supported by substantial evidence (more than a scintilla, less than a preponderance).
- Substantial-evidence review requires consideration of the record as a whole; an ALJ may not rely on selective readings of the evidence while disregarding significant contrary medical documentation.
- An ALJ must evaluate all medically determinable impairments and related symptoms that may affect work capacity, including the limiting effects of medication side effects when the record shows they may be significant.
- An RFC finding must be tied to the evidence; when an ALJ’s reading of medical records contains repeated misstatements or omissions, the RFC analysis cannot stand.
- Reversal with remand is appropriate when the administrative decision contains legal error or lacks substantial evidentiary support and further administrative evaluation is needed.

## Conclusion

Boatner v. Berryhill held that the SSA’s denial could not stand because the ALJ’s decision rested on an incomplete and inaccurate treatment of the medical record and failed to address the possible limiting effects of side effects from numerous prescribed medications; the court reversed and remanded for further proceedings.


Boatner v. Berryhill, 2018 WL 2191804 (2018)