Heather Gladys Marie H. v. Commissioner of Social Security Administration

Summary

The United States District Court for the District of Arizona reviewed the denial of a claimant’s application for Social Security disability insurance benefits. The court held that the Administrative Law Judge failed to adequately evaluate the consistency of a psychological consultative examiner’s opinion with the medical and nonmedical evidence. The court vacated the ALJ’s decision and remanded for further administrative proceedings.

Holdings

1. The challenge to the ALJ's partial discounting of Dr. Cunningham's opinion fails because Claimant challenged only the supportability analysis and did not challenge the ALJ's finding that the opinion was inconsistent with the medical record as a whole.
2. The ALJ erred by failing to explain whether Dr. Belton's opinion was consistent with evidence from other medical sources, including Dr. Zeuss's opinion, and with the record as a whole.
3. The ALJ did not err in discounting the challenged symptom testimony because the ALJ identified specific medical evidence showing normal or intact sensation and relied on Claimant's reported daily activities.
4. The error was harmful and required vacatur and remand because proper consideration of Dr. Belton's opinion could result in additional limitations, including a limitation to one- or two-step instructions, that might affect the disability determination.

Questions Presented

1. Whether the ALJ adequately evaluated the supportability and consistency of Dr. Keith Cunningham's physical opinion.
2. Whether the ALJ adequately evaluated the supportability and consistency of Dr. Maryanne Belton's psychological opinion.
3. Whether the ALJ provided legally sufficient reasons for discounting Claimant's testimony concerning disabling symptoms.
4. Whether any error in evaluating Dr. Belton's opinion was harmless.

Disposition

reversed_and_remanded