Jeffrey Hines suffered from Sickle Cell Disease, also known as sickle cell anemia. Mr. Hines applied for social security benefits. To obtain the benefits he had to show his condition prevented him from working a regular work week. A Social Security Administrative Law Judge ("ALJ") ruled that Mr. Hines could perform a wide range of sendentary work. According to the Fourth Circuit, however, the ALJ "applied an incorrect legal standard when he required objective evidence of pain."
The correct legal standard is: (1) once an applicant proves through objective evidence that he suffers a condition reasonably likely to cause pain (2) the applicant is entitled to rely exclusively on subjective evidence to prove the pain prevents him from working a regular work week.
Mr. Hines proved through blood work that he suffered from Sickle Cell Disease. His subjective evidence -- that he had to lie down "half a day" -- proved he could not work. As such, the Fourth Circuit reversed the ALJ and awarded Mr. Hines benefits.
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