Scott T. v. Frank Bisignano, Commissioner of Social Security

Summary

The U.S. District Court for the Eastern District of Washington reverses the Commissioner of Social Security’s denial of Title II disability benefits to Scott T. The court concludes that the administrative law judge erred in evaluating the plaintiff’s symptom allegations and a treating provider’s opinions. The matter is remanded for further proceedings, including a consultative physical examination.

Holdings

1. The ALJ consequentially erred by failing to meaningfully and fairly evaluate the supportability and consistency of PA-C Stiles's opinions, including by considering only that Plaintiff often appeared healthy while ignoring the full context of Stiles's statements, abnormal laboratory findings, treatment history, observed fatigue and balance problems, and medication side effects.
2. The ALJ's errors in evaluating Stiles's opinions affected the sequential disability analysis, including the evaluation of Plaintiff's reports of internal shaking, severe fatigue, shortness of breath, balance problems, wrist pain, and muscle paralysis with repetitive movements.
3. Remand was required for further development of the record, including an extended functional-capacity evaluation or consultative physical examination addressing Plaintiff's functional abilities with repeated activity.

Questions Presented

1. Whether the ALJ legally erred by inadequately evaluating the supportability and consistency of treating provider PA-C Stiles's medical opinions.
2. Whether the ALJ's errors in evaluating Stiles's opinions affected the evaluation of Plaintiff's symptom testimony and the sequential disability analysis.
3. Whether the record required further development through a consultative physical or extended functional-capacity examination.

Disposition

reversed_and_remanded