Martinez v. Kijakazi, No. 22-1820 (7th Cir. 2023)
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Martinez applied for supplemental security income. An ALJ reviewed the record and found that Martinez suffered from severe impairments but could nonetheless “perform the requirements of representative unskilled occupations such as a checker, routing clerk, and mail sorter.” After the Appeals Council denied Martinez’s request to review the decision, Martinez filed suit, then notified the Commissioner that the administrative record (pages within exhibit B15F) included medical records regarding a different claimant. In filing the administrative record with the court, the Commissioner noted that it was the full record. The pages relating to the other claimant were removed and replaced with a placeholder reading: “THIS PAGE WAS REMOVED AS AN EXHIBIT BY THE APPEALS COUNCIL BECAUSE IT DOES NOT REFER TO THE CLAIMANT.” Neither Martinez nor the district court saw the omitted pages. The Commissioner refused to produce the pages. Martinez moved to compel the Commissioner to include the full exhibit in the administrative record. The district court denied that motion, stating that “[t]he ALJ [only] cited the third-party records in exhibit B15F … as additional potential evidence that Mr. Martinez had an impairment.” The district court then affirmed the denial as supported by substantial evidence.
The Seventh Circuit reversed. The decision is not supported by substantial evidence because it relies on medical records belonging to someone other than Martinez; it is impossible to determine whether that error was harmless.
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