Daniel Skinner v. Frank Bisignano, Commissioner of Social Security

Summary

The document is a memorandum and recommendation from the U.S. District Court for the Eastern District of North Carolina addressing judicial review of the denial of Daniel Skinner’s Social Security disability benefits claims. The magistrate judge recommends remand because the Administrative Law Judge did not adequately explain why a limitation to three-step instructions, included in state-agency psychological consultants’ findings deemed somewhat persuasive, was omitted from the residual functional capacity assessments.

Holdings

1. The ALJ failed to adequately explain why the RFCs omitted the state-agency psychological consultants' limitation to three-step instructions after finding their opinions somewhat persuasive. The omission frustrated meaningful judicial review.
2. A limitation to three-step instructions creates an apparent conflict with jobs requiring GED reasoning level two, and the conflict could be outcome determinative in this case.

Questions Presented

1. Whether the ALJ adequately explained the omission of a three-step-instructions limitation from the RFC despite finding the state-agency psychological consultants' opinions somewhat persuasive.
2. Whether the omission could be harmless because the vocational expert identified jobs classified at GED reasoning level two.
3. Whether remand was required for further proceedings and a more complete explanation of the RFC and vocational analysis.

Disposition

remanded