Helms v. Social Security Administration, Commissioner

Angela D. Helms applied for Disability Insurance Benefits and Supplemental Security Income, claiming disability from degenerative disc disease, osteoarthritis, and chronic pain. After an Administrative Law Judge denied her claims, finding she could perform light work, Helms filed suit in the U.S. District Court for the Northern District of Alabama. She argued the ALJ improperly rejected her subjective pain testimony and failed to adequately evaluate medical opinions. On November 26, 2018, the court found the ALJ did not provide explicit, adequate reasons for discrediting Helms's descriptions of pain intensity and functional limitations, meaning the credibility assessment lacked substantial evidence under the Eleventh Circuit's pain standard. The court concluded the Commissioner's decision was not supported by proper legal articulation.

The court reversed the Commissioner's final decision and remanded the case to the Social Security Administration for further administrative proceedings consistent with the opinion.

Whether the Administrative Law Judge properly evaluated the claimant's subjective pain testimony and provided sufficient reasoning supported by substantial evidence when denying disability benefits.

The ruling reinforced the procedural requirement that ALJs must articulate specific, clear reasons for rejecting a claimant's subjective complaints of pain and their limiting effects. It serves as a citation for protecting due process in disability hearings, promoting consistent application of the pain standard and more transparent decision-making in Social Security adjudications.