Natalie M. v. Frank Bisignano, Social Security Administration

Summary

The United States District Court for the District of Maryland reviews the Social Security Administration’s denial of Natalie M.’s claims for disability insurance benefits and supplemental security income. The court reverses and remands under sentence four of 42 U.S.C. § 405(g), holding that the administrative decision improperly evaluated the claimant’s fibromyalgia symptoms by relying on objective evidence and conservative treatment in a manner inconsistent with Fourth Circuit precedent.

Holdings

1. The ALJ and Appeals Council improperly evaluated Plaintiff's fibromyalgia by relying on objective medical evidence and conservative treatment to discount her subjective symptom allegations without adequately explaining how that evidence undermined symptoms that are characteristic of a condition known to wax and wane and that cannot ordinarily be established through objective testing.
2. An RFC assessment must consider all of the claimant's physical and mental impairments and evaluate how they affect the claimant's ability to perform work-related functions on a regular and continuing basis, with a narrative explanation supported by the evidence.

Questions Presented

1. Whether the ALJ and Appeals Council supported the RFC determination with substantial evidence and applied the correct legal standard in evaluating Plaintiff's fibromyalgia symptoms.
2. Whether the ALJ improperly relied on objective medical findings and conservative treatment to discount Plaintiff's subjective reports of fibromyalgia-related pain and limitations.
3. Whether the RFC and resulting step-five determination were adequately supported in light of the allegedly improper evaluation of fibromyalgia.

Disposition

reversed_and_remanded