Raymond Bachmann v. Commissioner of Social Security

Summary

This Report and Recommendation addresses Raymond Bachmann’s appeal from the Commissioner of Social Security’s denial of disability benefits under Titles II and XVI of the Social Security Act. The magistrate judge recommends reversing and remanding the Commissioner’s decision, including in connection with the treatment of the plaintiff’s past relevant work and the opinion of examining neurologist Robert B. Barlow, M.D.

Holdings

1. The ALJ committed legal error by rejecting Dr. Barlow's opinion that Bachmann could stand or walk no more than four hours per day without acknowledging or adequately addressing the medical bases Barlow identified for that opinion, including left-sided weakness, peripheral neuropathy, impaired balance, and cane use.
2. Remand for further administrative proceedings and rehearing was appropriate because correcting the ALJ's error required reconsideration of the medical-opinion evidence and potentially other evidence, and it was not obvious from the record that Bachmann was disabled.

Questions Presented

1. Whether the ALJ provided legally sufficient, substantial-evidence-based reasons for rejecting Dr. Barlow's opinion concerning Bachmann's standing and walking limitations.
2. Whether the appropriate remedy for the ALJ's legal error was remand for further administrative proceedings rather than an immediate award of benefits.

Disposition

reversed_and_remanded