Andrew G. v. Frank Bisignano, Commissioner, Social Security Administration

Summary

The United States District Court for the District of Maryland reviewed the Social Security Administration’s denial of Andrew G.’s claim for Supplemental Security Income benefits. The court held that the Administrative Law Judge improperly relied on objective indicators, including mental-status examinations, to discount the severity of symptoms associated with depression, contrary to Fourth Circuit precedent. The court reversed the Commissioner’s decision and remanded the case for further proceedings under sentence four of 42 U.S.C. § 405(g).

Holdings

1. An ALJ may not rely on objective medical evidence, including normal clinical or mental-status findings, even as one of multiple factors, to discount a claimant's subjective complaints regarding symptoms of chronic depression.
2. The Commissioner's decision was reversed because of inadequate analysis and the case was remanded for further proceedings under sentence four of 42 U.S.C. § 405(g).

Questions Presented

1. Whether the ALJ improperly discounted Plaintiff's subjective symptoms of depression by relying on objective medical evidence and related clinical indicators.
2. Whether the ALJ's residual functional capacity assessment and step-five findings were supported by substantial evidence.

Disposition

reversed_and_remanded