## Facts

- John N. Mulvenna applied for Social Security disability insurance benefits under the Social Security Act, claiming disability based on serious heart disease and an unusual susceptibility to stress.
- On New Year’s Day 1988, Mulvenna suffered an acute myocardial infarction and was hospitalized for about 10 days, followed by cardiac treatment and rehabilitation.
- Mulvenna had worked for roughly 33 years in retail management, including high-responsibility work supervising hundreds of employees.
- Mulvenna asserted that, beyond his cardiac limitations, stress itself posed a dangerous risk: his personality and medical condition made work-related stress likely to trigger another infarction.
- Two treating physicians supported Mulvenna’s stress-based limitation, stating that any job could generate harmful stress for him and that the combined impairments were totally disabling; one physician warned a further infarction could be fatal.
- After initial denial and reconsideration, Mulvenna received a hearing before an administrative law judge (ALJ).
- The ALJ found that Mulvenna could not return to his prior retail-management job, but concluded he retained residual functional capacity to perform low-stress sedentary work existing in significant numbers in the regional economy.
- The ALJ’s decision became the final decision of the Secretary of Health and Human Services, Louis W. Sullivan, after administrative review, but the decision did not give a reasoned explanation for rejecting the treating-physician evidence about Mulvenna’s stress-related impairment.
- Mulvenna sought judicial review in the Northern District of Illinois under 42 U.S.C. § 405(g); both Mulvenna and the Secretary moved for summary judgment.

## Issues

1. Whether the Secretary’s denial of benefits could be sustained when the ALJ did not adequately address Mulvenna’s claim that the combination of his heart condition and special vulnerability to stress prevented any substantial gainful activity.
2. Whether remand was required because the ALJ failed to explain the treatment of (and reasons for discounting) treating-physician evidence supporting stress-based disability.

## Decision

- The court denied Mulvenna’s motion for summary judgment and denied the Secretary’s cross-motion for summary judgment.
- The court remanded the case to the Secretary for further proceedings.
- The court directed reconsideration of Mulvenna’s theory that he was disabled by the combination of his heart condition and his special vulnerability to stress, with proper evaluation and explanation of the medical evidence on that point.

## Legal Principles

- On review under 42 U.S.C. § 405(g), a court examines whether the agency applied the correct legal standards and whether the decision is supported by substantial evidence.
- An ALJ must evaluate all medically determinable impairments and their combined effect, including nonexertional limits such as an inability to tolerate work-related stress.
- Treating-physician opinions generally receive significant weight, and an ALJ must give stated, reviewable reasons for rejecting or discounting such opinions.
- A denial of benefits cannot stand where the ALJ fails to address a material line of evidence or fails to explain why significant medical evidence was rejected; in that situation, the proper remedy is typically remand for a reasoned decision.

## Conclusion

Mulvenna v. Sullivan remanded a Social Security disability denial because the ALJ did not adequately explain why he rejected treating-physician evidence that Mulvenna’s heart disease, together with an unusual vulnerability to stress, prevented him from performing even low-stress sedentary jobs; without a reasoned treatment of that evidence and theory of disability, the court could not uphold the Secretary’s final decision.


Mulvenna v. Sullivan, 796 F. Supp. 325 (1992)