Angela O. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Maryland reviewed the denial of Angela O.'s claim for disability insurance benefits. The court held that the Administrative Law Judge inadequately explained the consistency analysis of a physical therapist's medical opinion, reversed the Commissioner's decision in part, and remanded for further proceedings under sentence four of 42 U.S.C. § 405(g).

Holdings

1. The ALJ's evaluation of Hoffman's opinion was inadequate because, although the ALJ addressed supportability and consistency in general terms, the ALJ did not explain how the opinion was inconsistent with the identified treating-source objective evidence. That unexplained consistency analysis frustrated meaningful judicial review and required remand.
2. The court declined to address the alternative argument concerning mental impairments and expressed no opinion on the ultimate issue of disability.

Questions Presented

1. Whether the ALJ adequately evaluated the supportability and consistency of Christopher Hoffman's medical opinion under 20 C.F.R. § 404.1520c.
2. Whether the court should address Angela O.'s alternative argument that the ALJ inadequately assessed her mental impairments under 20 C.F.R. § 404.1520a.

Disposition

reversed_and_remanded