Summary
The United States District Court for the District of Maryland reviews the denial of Anthony Gray’s claims for disability insurance benefits and supplemental security income. The court holds that the Administrative Law Judge’s residual functional capacity analysis, particularly the two-hour limitation on concentration, persistence, and pace, lacks an adequate logical explanation supported by substantial evidence. The court reverses and remands the Social Security Administration’s decision under sentence four of 42 U.S.C. § 405(g).
Holdings
- The ALJ's RFC determination was not supported by substantial evidence because the decision did not provide a sufficient narrative explanation connecting the evidence to its conclusions.
- The ALJ failed to explain how the evidence supporting moderate limitations in concentration, persistence, and pace translated into the specific finding that Plaintiff could maintain concentration, persistence, and pace for two hours at a time.
Questions Presented
- Whether the ALJ's residual functional capacity determination was supported by substantial evidence and adequately explained.
- Whether the ALJ adequately connected the evidence of moderate limitations in concentration, persistence, and pace to the RFC limitation permitting Plaintiff to concentrate, persist, and maintain pace for two hours at a time.
Disposition
reversed_and_remanded
Cases Cited (16)
- Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001)(followed)
- Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996)(followed)
- Mascio v. Colvin, 780 F.3d 632, 634-36, 638 (4th Cir. 2015)(followed)
- Lewis v. Berryhill, 858 F.3d 858, 862 (4th Cir. 2017)(followed)
- Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012)(followed)
- Johnson v. Barnhart, 434 F.3d 650, 653 (4th Cir. 2005)(followed)
- Rodney M. v. Kijakazi, No. CV 23-0947-CDA, 2024 WL 1097192, at *3 (D. Md. Mar. 13, 2024)(followed)
- Thomas v. Berryhill, 916 F.3d 307, 311 (4th Cir. 2019)(followed)
- Monroe v. Colvin, 826 F.3d 176, 188-89 (4th Cir. 2016)(followed)
- Dowling v. Commissioner of Social Security Administration, 986 F.3d 377, 387-88 (4th Cir. 2021)(followed)
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