Carmen F. v. Frank Bisignano, Commissioner, Social Security Administration

Summary

The United States District Court for the District of Maryland grants Plaintiff’s motion for summary judgment and remands a Social Security disability benefits case under sentence four of 42 U.S.C. § 405(g). The court holds that the ALJ failed to conduct and explain a function-by-function assessment of the claimant’s ability to sit, stand, and walk, despite contradictory evidence concerning those limitations. The court does not reach the claimant’s remaining arguments but directs the Commissioner to address them on remand.

Holdings

1. The ALJ failed to conduct the required function-by-function analysis of Plaintiff's ability to perform work-related activities, particularly walking, standing, and sitting.
2. The ALJ's general discussion of impairments and medical opinions did not satisfy the requirement to provide a narrative discussion connecting the evidence to conclusions about Plaintiff's capacity to sit, stand, and walk.
3. The ALJ's failure to assess Plaintiff's ability to walk, stand, and sit was not harmless and warranted remand.

Questions Presented

1. Whether the ALJ adequately assessed Plaintiff's residual functional capacity by conducting a function-by-function analysis of her ability to perform work-related activities, particularly sitting, standing, and walking.
2. Whether the ALJ's RFC determination was supported by a narrative discussion logically connecting the evidence to the RFC conclusions.
3. Whether the ALJ's failure to assess sitting, standing, and walking was harmless.
4. Whether the court needed to reach Plaintiff's challenge to the ALJ's evaluation of her subjective complaints.

Disposition

reversed_and_remanded