My Favorite Judicial Opinion

Judge Carlton Reeves of the Southern District of Mississippi has written some real bangers in his career, but his magnum opus might be his 2018 opinion in Boatner v. Berryhill, an appeal of the Social Security Administration’s denial of disability benefits for a Mississippi man named Carl Boatner. Judge Reeves finds that Social Security wrongly denied Boatner’s claim.

The 26 page decision spends most of its ink reviewing, step by step, why it took the better part of a decade for Boatner to receive the benefits to which he is entitled. This recitation is exhaustive but also breathtaking in its clarity. Headings like “Did Boatner’s ALJ Review the Evidence Properly?” are followed by single-word paragraphs: “No.”

Reeves paints a damning picture of what happens when an administrative process is deprived of the resources to fairly evaluate cases like Boatner’s. He concludes, “Doing justice means finding truth. Finding truth takes empathy, expertise, and time. Without those resources, people who decide disability cases are doomed to do injustice.”

It’s worth reading in full. But the introduction is perfection in its plain acknowledgement of the facts of Boatner’s life and in its determination to not waste a second more of his time.

Carl Boatner spends much of his life waiting. He waits to catch his breath after walking a few dozen steps. He waits for family and friends to assist him in shaving and taking medications. He waits on car rides in rural Mississippi to his many doctor’s appointments. He waits in parking lots while others shop for him, afraid of having a medical emergency in public.

Boatner’s diagnoses include coronary artery disease, two liver diseases, diabetes, obesity, hypertension, spine disorders, major depressive disorder, and anxiety disorder. In 2015, Boatner received a terminal diagnosis of chronic obstructive pulmonary disease, but survived a months-long stay in hospice care.

Even before entering hospice care, doctors described Boatner as “chronically ill” and “disabled.” Between 2011 and 2015, they prescribed him about 17,000 pills. Boatner, now 52, uses oxygen tanks and other devices to help him breathe. He has had a number of strokes and heart attacks, with stents across his heart and liver, and recently had triple-bypass heart surgery. Around 2000, a heart attack ended his two-decade long career as a truck driver. He has not had a steady job since. Boatner last applied for a job in 2015 as a yard hand, but was rejected because the employer thought he “couldn’t hold up.”

Boatner has spent nearly a decade seeking disability payments from the Social Security Administration, filing his last application in 2014. Despite acknowledging the severity of Boatner’s medical conditions and his trips to death’s doorstep, the Administration has denied each of his four applications. These denials have been painful. One caused Boatner to walk out of his house, put a gun to his head, and threaten to kill himself.

Boatner filed this lawsuit to challenge the latest denial. No lengthy judicial opinion need resolve that challenge. Boatner plainly qualifies for disability payments.

But Boatner’s story is worth telling in full. It reveals a disability payment system tasked with managing millions of cases each year, yet stripped of the resources to decide those cases fairly. As Justice Thurgood Marshall once wrote, such an “unnecessary barrie[r]” to people with disabilities “stymie[s] recognition of [their] dignity and individuality,” and therefore requires careful review. Furthermore, the disability payment system aims to be “as protective of people’s dignity as possible,” a purpose “courts must give ‘due regard for.’” The Court must explore why, until today, the disability payment system has left Boatner waiting.

https://www.courtlistener.com/docket/6636939/19/boatner-v-colvin/