Tieniber v. Heckler

In 1981, petitioner filed an application with the Secretary of Health and Human Services (Secretary) for Social Security disability benefits under the Social Security Act, 42 U.S.C. § 301 et seq. (""Act""). The Secretary denied petitioner's application, claiming that she did not meet the disability requirements. Upon reconsideration, the Secretary reached the same conclusion, and petitioner filed a request for a hearing before an administrative law judge (ALJ) of the Bureau of Hearings and Appeals. After considering objective medical evidence of and subjective testimony concerning petitioner's various alleged disabilities, the ALJ concluded that petitioner failed to establish a disability for purposes of the Act. Pursuant to 42 U.S.C. § 405(g), petitioner then commenced a civil action for review of the Secretary's decision in the district court, contending that the ALJ had made inadequate findings to refute the uncontradicted subjective evidence of petitioner's disability. The magistrate agreed with petitioner, and recommended reversing the Secretary's decision. The district court rejected the magistrate's recommendation and affirmed the Secretary's denial, noting that, although the ALJ did not specifically explain why he rejected the testimony, the record reflected sufficient consideration of the subjective evidence to uphold the ALJ's ultimate finding. The sole issue presented on this appeal is whether, absent a clear credibility determination as to the subjective testimony of petitioner and her daughter, the ALJ's findings were sufficient to uphold his rejection of the claimant's subjective evidence of disability. We have jurisdiction. 28 U.S.C. § 1291; 42 U.S.C. § 405(g). I.