Danielle W. v. Frank Bisignano, Commissioner, Social Security Administration

Summary

The United States District Court for the District of Maryland reviews the denial of Danielle W.'s applications for Disability Insurance Benefits and Supplemental Security Income. The court holds that the Administrative Law Judge improperly relied on objective medical findings to discount subjective symptoms associated with major depressive disorder, contrary to Fourth Circuit precedent. The court reverses the Commissioner's decision and remands the case for further proceedings under sentence four of 42 U.S.C. § 405(g).

Holdings

1. An ALJ may not rely on objective medical evidence, even as one factor among several, to discount a claimant's subjective complaints regarding symptoms of chronic depression or major depressive disorder.
2. The ALJ's decision was not supported by substantial evidence because the ALJ improperly increased Plaintiff's burden of proof by effectively requiring objective medical validation of subjective statements concerning her depressive symptoms.

Questions Presented

1. Whether the ALJ improperly evaluated Plaintiff's subjective complaints by relying on objective medical evidence to discount symptoms of major depressive disorder.
2. Whether the ALJ's evaluation of Plaintiff's symptoms and resulting residual functional capacity determination was supported by substantial evidence and complied with governing Fourth Circuit precedent.

Disposition

reversed_and_remanded