David M. v. Frank Bisignano, Commissioner of Social Security

Summary

The U.S. District Court for the Eastern District of Washington reversed the Administrative Law Judge’s denial of Title II Social Security disability benefits and remanded for further proceedings. The court held that the ALJ consequentially erred in evaluating the plaintiff’s symptom reports and medical opinions, including by misreading records concerning a spinal cord stimulator, pulmonary symptoms, fluctuating mental-health symptoms, and medication side effects. The court directed further development of the record, including obtaining medical records after November 2022 and ordering a consultative physical examination.

Holdings

1. The ALJ consequentially erred by discounting Plaintiff's reported symptoms without a clear and convincing rationale supported by substantial evidence.
2. The ALJ's finding that Dr. Shirley Deem's opinion was unpersuasive, and the related consistency evaluations of the administrative medical findings, were not supported by substantial evidence.
3. Because the errors were consequential and affected the RFC and nondisability determination, remand for further proceedings rather than affirmance was required.

Questions Presented

1. Whether the ALJ provided legally sufficient, substantial-evidence-based reasons for discounting Plaintiff's symptom testimony.
2. Whether the ALJ properly evaluated the supportability and consistency of Dr. Shirley Deem's medical opinion and the administrative medical findings.
3. Whether the errors in evaluating symptoms and medical opinions affected the RFC and nondisability determination.
4. Whether remand for further administrative proceedings, including development of the record and a consultative physical examination, was warranted.

Disposition

reversed_and_remanded