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Lidy v. Sullivan

United States Court of Appeals, Fifth Circuit
Sep 17, 1990
911 F.2d 1075 (5th Cir. 1990)

Summary

holding that a claimant requesting that a reporting physician be subpoenaed has an absolute due process right to cross-examine such physician

Summary of this case from Yancey v. Apfel

Opinion

No. 90-1158. Summary Calendar.

September 17, 1990.

Robert E. Barfield, Amarillo, Tex., for plaintiff-appellant.

Joseph B. Liken and Karen J. Sharp, H HS/OGC, Dallas, Tex., for plaintiff-appellant.

Appeal from the United States District Court for the Northern District of Texas.

Before GEE, SMITH, and WIENER, Circuit Judges.


I.

The plaintiff, Nelley Lidy, Jr., appeals the district court's grant of summary judgment upholding the denial by the Secretary of Health and Human Services of Lidy's application for disability insurance benefits. The factual issue regarding Lidy's entitlement to benefits is whether he suffers disabling pain. On this point, the following witnesses testified: Lidy, his wife, Dr. Berg, Dr. Morgan, and Dr. Finney. The reports of Dr. Finney, to whom Lidy's worker's compensation insurer referred him, formed the basis of the administrative law judge's (ALJ's) finding of no disability.

In order to challenge Dr. Finney's report, Lidy sought to subpoena him for cross-examination. The ALJ refused Lidy's request but did permit him to submit a set of written interrogatories to Dr. Finney. Finding the doctor's answers to be vague and evasive, Lidy sought to submit a second set of interrogatories and to reurge his request for live cross-examination. The ALJ denied Lidy's request, stating that additional interrogatories would not be helpful.

In the district court, the magistrate recommended granting Lidy's motion for summary judgment on the ground that the ALJ's refusal to permit Lidy to cross-examine Dr. Finney constituted a denial of due process. The district court, however, sustained the Secretary's objections to that finding and held that the ALJ acted within his discretion; the court accordingly granted summary judgment in favor of the Secretary.

II.

In concluding that Lidy has a right to cross-examine Dr. Finney, the magistrate relied upon Richardson v. Perales, 402 U.S. 389, 402, 91 S.Ct. 1420, 1428, 28 L.Ed.2d 842 (1971):

We conclude that a written report by a licensed physician who has examined the claimant and who sets forth in his report his medical findings in his area of competence may be received as evidence in a disability hearing and, despite its hearsay character and an absence of cross-examination, and despite the presence of opposing direct medical testimony and testimony by the claimant himself, may constitute substantial evidence supportive of a finding by the hearing examiner adverse to the claimant, when the claimant has not exercised his right to subpoena the reporting physician and thereby provide himself with the opportunity for cross-examination of the physician. [Emphasis added.]

Lidy maintains that this holding recognizes an absolute right to cross-examine such a physician when a subpoena has been sought.

The Secretary argues, first, that Perales addresses the scenario of a nonexamining physician, whereas here Dr. Finney in fact had examined Lidy. However, the passage from Perales that we have quoted, supra, plainly refers to examining physicians. Hence, this argument by the Secretary is without merit.

The Secretary also suggests that the rule should be different for a doctor who, like Dr. Finney and unlike the doctor in Perales, is a treating physician. However, nothing in Perales supports that distinction.

Second, the Secretary observes that, in what he acknowledges is dictum, the Court in Perales referred to "the cost of providing live medical testimony ... where need has not been demonstrated by a request for a subpoena." Id. at 406, 91 S.Ct. at 1430. It is not pellucid from this passage, standing alone, whether the Court meant that the request must contain sufficient demonstration of need (the interpretation undoubtedly supported by the Secretary) or merely that the filing of a request ipso facto constitutes a demonstration of need.

We note, however, that later in its opinion the Court refers to "the use of the subpoena and consequent cross-examination," id. at 410, 91 S.Ct. at 1431, suggesting that such cross-examination necessarily follows from the filing of a request for a subpoena. We also observe that in the major passage at issue, the Court refers to the "right to subpoena," id. at 402, 91 S.Ct. at 1427-28, not merely the "right to request a subpoena," thus implying that the entitlement to a subpoena is automatic. Thus, we conclude that the better reading is that by requesting a subpoena, a claimant has the right to cross-examine an examining physician.

In accordance with the view that the right to subpoena is qualified, the Secretary has promulgated 20 C.F.R. § 404.950(d), permitting an ALJ to refuse a request for a subpoena of a witness whose testimony is not "reasonably necessary for the full presentation of the case," a showing that Lidy failed to make. In view of our conclusion that Lidy's request should have been honored, we need not address this point further.

We are persuaded, as well, by the fact that all of the circuit courts of appeals that have addressed this issue read Perales as conferring an absolute right to subpoena a reporting physician. "Due process requires that a claimant be given the opportunity to cross-examine and subpoena the individuals who submit reports." Coffin v. Sullivan, 895 F.2d 1206, 1212 (8th Cir. 1990). "We construe [ Perales] as holding that an opportunity for cross-examination is an element of fundamental fairness of the hearing to which a claimant is entitled...." Wallace v. Bowen, 869 F.2d 187, 192 (3d Cir. 1989). Accord Townley v. Heckler, 748 F.2d 109, 114 (2d Cir. 1984). See Figueroa v. Secretary of Health, Education Welfare, 585 F.2d 551, 554 (1st Cir. 1978) ("right to cross-examine"). We see no reason to create a split among the circuits on this issue by differing with these persuasive authorities.

Accordingly, we VACATE and REMAND to the district court for further proceedings in light of our determination that Lidy was entitled to cross-examine Dr. Finney.


Summaries of

Lidy v. Sullivan

United States Court of Appeals, Fifth Circuit
Sep 17, 1990
911 F.2d 1075 (5th Cir. 1990)

holding that a claimant requesting that a reporting physician be subpoenaed has an absolute due process right to cross-examine such physician

Summary of this case from Yancey v. Apfel

holding that an absolute right to subpoena exists

Summary of this case from Flatford v. Chater

holding social security claimants have an absolute right to cross-examine a reporting physician

Summary of this case from Ouk v. Berryhill

recognizing a claimant's absolute due process right to cross-examine an examining physician upon requesting a subpoena

Summary of this case from Carolyn M. v. Saul

noting that "all of the circuit courts of appeals that have addressed this issue read Perales as conferring an absolute right to subpoena a reporting physician"

Summary of this case from Doe v. the United States

examining physicians

Summary of this case from Salami v. Kijakazi

explaining that the ALJ may refuse a request for a subpoena when the evidence "is not reasonably necessary for the full presentation of the case"

Summary of this case from Westfall v. Berryhill

In Lidy, the panel focused on language from a Supreme Court case, Richardson v. Perales, 402 U.S. 389, 402 (1971), specifically articulating the claimant had the "right to subpoena the reporting physician and thereby provide himself with the opportunity for cross-examination of the physician."

Summary of this case from Marin v. Berryhill

explaining that the ALJ may refuse a request for a subpoena when the evidence "is not 'reasonably necessary for the full presentation of the case'"

Summary of this case from Prince v. Berryhill

explaining that the opportunity for cross-examination is the "element of fundamental fairness of a hearing to which a claimant is entitled."

Summary of this case from Westbrook v. Colvin

In Lidy, however, the plaintiff was wholly denied the opportunity to cross-examine the vocational expert witness, at all.

Summary of this case from Rouner v. Colvin

In Lidy, the Fifth Circuit held that due process entitles a disability claimant to cross examine individuals whose reports are considered as evidence in the disability determination.

Summary of this case from Ballard v. Astrew
Case details for

Lidy v. Sullivan

Case Details

Full title:NELLEY LIDY, JR., PLAINTIFF-APPELLANT, v. LOUIS W. SULLIVAN, M.D.…

Court:United States Court of Appeals, Fifth Circuit

Date published: Sep 17, 1990

Citations

911 F.2d 1075 (5th Cir. 1990)

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