Summary
This memorandum opinion from the U.S. District Court for the Middle District of Pennsylvania reviews an Administrative Law Judge’s denial of Social Security disability benefits for the plaintiff, Susan Delea. The court examines the ALJ’s evaluation of medical opinion evidence and residual functional capacity determinations regarding Delea’s mental health impairments. Concluding that the ALJ’s decision lacked substantial evidence, the court reverses the denial and remands the case to the Commissioner for further proceedings.
Topics
Practice areas
Questions Presented
- Whether the ALJ’s decision is supported by substantial evidence under the standard of review
- Whether the ALJ properly considered the medical opinion evidence in forming the RFC determination
Holdings
- The court held that the ALJ’s RFC determination and overall denial are not supported by substantial evidence and therefore remands the matter for further consideration.
Factual background
Susan Delea, a 44‑year‑old former waitress, alleged severe mental health impairments including borderline personality disorder, schizoaffective disorder, bipolar disorder, and PTSD. The record contains extensive psychiatric treatment notes, multiple inpatient hospitalizations, and conflicting medical opinions regarding the severity of her limitations.
Procedural history
Delea filed a disability claim in May 2020. An Administrative Law Judge denied the claim, and the Appeals Council remanded. The ALJ issued a final denial on March 14, 2024. Delea now challenges the ALJ's decision in district court.
Remand instructions
Remand to the Commissioner for further consideration of the ALJ’s RFC determination, including a proper analysis of the medical opinion evidence and whether the claimant’s mental impairments contributed to medication non‑compliance.