## Facts

- A father applied for Supplemental Security Income on behalf of his minor son, alleging disability from severe ADHD and related behavioral and emotional problems.
- The child was treated by a pediatrician who diagnosed ADHD and prescribed stimulant medication beginning in 1994, with multiple dosage adjustments over several years and reported adherence difficulties.
- The child also received psychiatric treatment through a community mental health center; records described violent behavior, suicidal talk, school fighting, and bedwetting, with additional symptoms including depression, anxiety, paranoia, and episodes of suicidal and homicidal ideation, including hospitalization.
- School records documented frequent and serious misconduct; in one year the child accumulated 24 disciplinary reports for disruption, threats, fighting, sexual assault, and suspensions.
- An Administrative Law Judge found the child had “severe” impairments but concluded they did not meet, medically equal, or functionally equal a listed impairment; the Appeals Council denied review.
- The father sought judicial review under 42 U.S.C. § 405(g), challenging whether the non-disability finding was supported by substantial evidence on the record as a whole.

## Issues

1. Whether substantial evidence supported the ALJ’s conclusion that the child’s severe ADHD and related emotional/behavioral conditions did not meet or medically equal a listed impairment.
2. Whether the ALJ properly assessed functional equivalence to the listings in light of the medical and school evidence of significant limitations.

## Decision

- The district court reversed the Commissioner’s denial of benefits.
- The court held the ALJ’s finding that the impairments did not meet or equal a listing (including via functional equivalence) was not supported by substantial evidence on the record as a whole.
- The case was remanded for further proceedings consistent with the opinion, effectively requiring benefits if the agency applied the court’s evidentiary assessment.

## Legal Principles

- Under 42 U.S.C. § 405(g), a reviewing court asks whether the Commissioner applied the correct legal standards and whether the decision is supported by substantial evidence on the record as a whole.
- A child is disabled for Title XVI purposes if a medically determinable severe impairment meets, medically equals, or functionally equals a listed impairment.
- Longitudinal treating-source evidence and detailed school records are probative in evaluating childhood mental impairments and functional limitations.
- Evidence that symptoms persist despite sustained treatment efforts can support listing-level severity and may undercut a finding that medication sufficiently controls the impairment.
- The listings and functional-equivalence inquiry require consideration of the combined effect of the evidence, not a piecemeal evaluation that minimizes corroborated limitations.

## Conclusion

The court set aside the agency’s non-disability finding because the longitudinal medical record and extensive school discipline evidence showed severe, persistent ADHD and emotional/behavioral dysfunction producing marked limitations, and the ALJ’s contrary equivalence analysis could not be reconciled with substantial evidence on the record as a whole.


Roelandt ex rel. Roelandt v. Apfel, 125 F. Supp. 2d 1138 (S.D. Iowa 2001)