Cleta S. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Maryland reviewed the denial of Cleta S.'s applications for disability insurance benefits and Supplemental Security Income. The court held that the Administrative Law Judge failed to perform the function-by-function residual functional capacity assessment required by SSR 96-8p and that the deficiency frustrated meaningful judicial review. The court denied both parties' motions for summary judgment, 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 failed to conduct the required function-by-function assessment of the claimant’s work-related abilities. Merely evaluating symptoms and assigning a general RFC category, such as light work, does not satisfy the requirement to explain the claimant’s capacity for functions including lifting, carrying, pushing, pulling, sitting, standing, and walking.
2. The claimant was not required to identify evidence that would necessarily compel a more restrictive RFC because the ALJ’s failure to follow the function-by-function framework itself frustrated meaningful judicial review.
3. The court declined to reach the claimant’s remaining arguments because the inadequate RFC analysis independently required remand.

Questions Presented

1. Whether the ALJ adequately evaluated the claimant’s residual functional capacity by conducting the required function-by-function assessment of her work-related physical and mental abilities.
2. Whether the ALJ’s RFC determination was supported by substantial evidence and explained sufficiently to permit meaningful judicial review.
3. Whether the court should address the claimant’s remaining challenges to the Commissioner’s decision.

Disposition

reversed_and_remanded