Karla S. M. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Kansas reviewed the denial of Karla S. M.’s claim for Social Security Disability Insurance benefits for the period before January 4, 2020. The court remanded the Commissioner’s decision under the fourth sentence of 42 U.S.C. § 405(g), concluding that further proceedings were warranted concerning the ALJ’s assessment of the claimant’s residual functional capacity and ability to interact with supervisors.

Holdings

1. The court remanded because the record and decision did not adequately establish the functional findings underlying the ALJ's light-work RFC determination, and resolving the issue would require the Commissioner rather than the court to perform the necessary disability analysis.
2. The court remanded because the ALJ addressed interaction with coworkers and the public but did not address Plaintiff's ability to interact with, accept instruction from, or respond to criticism from supervisors, leaving the court unable to resolve the disability determination without drawing an impermissible additional inference.
3. The case should be remanded for further proceedings, not for an immediate calculation and award of benefits.

Questions Presented

1. Whether the ALJ adequately assessed Plaintiff's residual functional capacity on a function-by-function basis before assigning a light-work exertional category.
2. Whether the ALJ adequately addressed Plaintiff's ability to interact with supervisors after finding moderate limitations in interacting with others and evaluating a consultative psychologist's opinion.
3. Whether the case should be remanded for further administrative proceedings or for an immediate award of benefits.

Disposition

remanded