## Facts

- Daniel J. Schaal applied for Disability Insurance Benefits and Supplemental Security Income, alleging disability beginning May 30, 1991 due to schizoaffective disorder.
- Schaal was born in 1951, had a business degree and partial graduate coursework, lived with his parents, and performed limited volunteer work a few hours per week.
- His prior jobs included hotel desk clerk, bottle return clerk, restaurant work, and valet parking attendant.
- The record included conflicting functional evidence: Schaal reported relatively intact daily activities (self-care, shopping, chores, public transportation), while his father reported isolation, inconsistent self-care without coaxing, limited independent task completion, and intermittent sleeplessness.
- A social worker who counseled and supervised Schaal in a work-like setting testified that he could not sustain regular, competitive employment due to poor concentration, inability to follow complex instructions or make quick decisions, need for constant supervision, and anxiety-related behaviors.
- The ALJ found Schaal’s mental impairment “severe” but concluded it did not meet or equal the relevant mental-impairment listing and that Schaal was not disabled.
- In the written decision, the ALJ did not discuss the questionnaires from Schaal or his parents and mentioned the social worker’s testimony only briefly.

## Issues

1. Whether the Commissioner’s denial of benefits was supported by substantial evidence and applied correct legal standards under 42 U.S.C. § 405(g).
2. Whether the ALJ impermissibly ignored or inadequately evaluated significantly probative evidence bearing on Schaal’s functional limitations and ability to sustain competitive work.

## Decision

- The district court denied the Commissioner’s motion to affirm.
- The court granted Schaal’s motion only to the extent of remand for further administrative proceedings.
- The court held that the denial decision, as explained, was not supported by substantial evidence when the record was considered as a whole.
- The court declined to order an immediate award of benefits because the record did not compel a disability finding without further agency analysis.

## Legal Principles

- Under 42 U.S.C. § 405(g), the Commissioner’s findings are conclusive only if supported by substantial evidence, assessed on the record as a whole.
- An ALJ may not silently disregard significantly probative evidence that could affect the disability determination, even though the ALJ need not discuss every item in the record.
- A listings determination and residual functional evaluation must be explained with enough specificity to permit meaningful judicial review, including a reasoned treatment of conflicting evidence.
- Reliance on benign descriptions of daily activities cannot substitute for a reasoned evaluation of contrary evidence suggesting inability to perform sustained, competitive work.

## Conclusion

The court remanded because the ALJ’s written rationale did not adequately address material evidence—especially lay questionnaires and a social worker’s observations—undermining the substantial-evidence basis for denying benefits, while leaving the ultimate disability determination for further administrative proceedings.


Schaal v. Callahan, 993 F. Supp. 85 (D. Conn. 1997)