Summary
This United States District Court memorandum and order reviews an Administrative Law Judge’s denial of Social Security Disability Insurance benefits for plaintiff Michelle White. The court finds that the ALJ’s residual functional capacity assessment lacked sufficient medical evidence and analytical support to justify a conclusion that the plaintiff could perform light work. Consequently, the court reverses the Commissioner’s decision and remands the case for further proceedings consistent with its findings.
Topics
Practice areas
Questions Presented
- Whether the ALJ’s residual functional capacity (RFC) determination was supported by substantial evidence.
- Whether the ALJ erred in finding that the plaintiff was not disabled under the Social Security Act.
Holdings
- The court holds that the ALJ’s RFC determination was not supported by substantial evidence and therefore reverses and remands for further evidentiary development.
- The court holds that the ALJ erred in concluding the plaintiff was not disabled and reverses the Commissioner’s decision.
Key quotations
“‘Substantial evidence is less than a preponderance, but is enough that a reasonable mind would find it adequate to support the Commissioner’s conclusion.’”
“The ALJ did not undergo this process here.”
Factual background
Michelle White, born May 1, 1967, alleged disabling conditions including spinal stenosis, surgery, arrhythmia, depression, and other ailments. She worked as a paramedic lifting over 50 pounds and previously as a nursing assistant. She testified about pain levels, limited ability to walk, stand, lift, and perform daily activities during the relevant period (Jan 2, 2018 – Sep 30, 2020).
Procedural history
Plaintiff filed for Social Security disability benefits in July 2022. The SSA denied the claim, the ALJ affirmed denial, and the Appeals Council denied review. Plaintiff exhausted administrative remedies and filed suit in the Eastern District of Missouri.
Remand instructions
Remand to the Commissioner to more fully identify, evaluate, and supplement the medical and non‑medical evidence supporting the RFC determination, consider ordering a medical expert review of the record, and possibly require the plaintiff to complete a Function Report.