Ashley B. v. Frank Bisignano, Commissioner, Social Security Administration

Summary

The United States District Court for the District of Maryland reversed the Commissioner of Social Security’s denial of Ashley B.’s claim for Disability Insurance Benefits and remanded for further proceedings. The court held that the Administrative Law Judge inadequately analyzed whether the plaintiff’s bladder issues, including alleged neurogenic bladder and related bathroom-break limitations, constituted a medically determinable impairment and whether they should be considered in the residual functional capacity assessment. The court expressed no opinion on the ultimate entitlement to benefits.

Holdings

1. The ALJ’s analysis was inadequate because the decision did not explain why Plaintiff’s bladder issues did not constitute a medically determinable impairment and relied primarily on the absence of urologist treatment without adequately addressing the evidence in the record.
2. The error was not harmless because the ALJ did not adequately consider Plaintiff’s bladder issues or possible neurogenic bladder at any step of the sequential evaluation.

Questions Presented

1. Whether the ALJ adequately analyzed whether Plaintiff’s bladder symptoms, including alleged neurogenic bladder and urinary urgency, constituted a medically determinable impairment.
2. Whether the ALJ adequately considered Plaintiff’s bladder-related symptoms and alleged need for additional bathroom breaks in assessing residual functional capacity.
3. Whether the ALJ’s inadequate analysis was harmless because the ALJ found at least one other severe impairment and proceeded through the remaining steps.

Disposition

reversed_and_remanded