Louis L. v. Frank Bisignano, Commissioner of Social Security

Summary

This Report and Recommendation concerns a Social Security disability benefits action brought by Louis L. against the Commissioner of Social Security. The court recommends granting the plaintiff’s motion and denying the Commissioner’s motion because the Administrative Law Judge did not adequately account for the plaintiff’s moderate limitations in concentration, persistence, and pace in the residual functional capacity assessment and vocational-expert hypotheticals.

Holdings

1. A restriction to simple, routine tasks, even when combined with a restriction against production-rate work, does not adequately account for a claimant's moderate limitations in concentration, persistence, and pace without additional limitations or an adequate explanation tying the RFC to those limitations.
2. A vocational-expert hypothetical must accurately describe the claimant's impairments, including material concentration, persistence, and pace limitations; failure to do so may constitute reversible error.
3. Remand for a new administrative hearing was warranted because the ALJ failed to adequately explain or incorporate Plaintiff's moderate CPP limitations into the RFC and vocational-expert hypothetical.

Questions Presented

1. Whether the ALJ adequately accounted for Plaintiff's moderate limitations in concentration, persistence, and pace in the RFC.
2. Whether the ALJ's hypothetical questions to the vocational expert accurately described Plaintiff's mental limitations.
3. Whether the ALJ's failure to explain how the RFC addressed Plaintiff's concentration, persistence, and pace limitations required remand.

Disposition

remanded