Supplemental Security Income Application

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7^th Circuit Court of Appeals

Case Name: Rene Martinez v. Kilolo Kijakazi

Case No.: 22-1820

Officials: Flaum, Rovner, and St. Eve, Circuit Judges.

Focus: Supplemental Security Income Application

Martinez applied for supplemental security income, and an Administrative Law Judge (ALJ) determined that Martinez had severe impairments but could still perform certain unskilled occupations. Martinez filed a lawsuit after the Appeals Council denied his request for review. During the litigation, Martinez notified the Commissioner that the administrative record contained medical records related to a different claimant. The Commissioner provided the court with an incomplete exhibit, removing the pages related to the other claimant and stating that they were not relevant to Martinez’s case. Neither Martinez nor the district court were aware of the omitted pages. Martinez requested the Commissioner to include the complete exhibit, but the district court denied the motion, upholding the denial of benefits as supported by substantial evidence.

The Seventh Circuit disagreed and reversed the decision. The use of medical records belonging to someone other than Martinez undermines the support for the decision, and it is unclear whether this error was harmless. The court found that the decision lacked substantial evidence due to this reliance on unrelated medical records.

Vacated and Remanded.

Decided 06/29/23

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