Derek M. v. Frank Bisignano, Commissioner, Social Security Administration

Derek M. · United States District Court for the District of Maryland · March 18, 2026 · No. Civil No. 24-3520-DRM

Summary

The United States District Court for the District of Maryland reviews the Social Security Administration’s denial of Derek M.’s claim for Disability Insurance Benefits. The court reverses the Commissioner’s decision and remands for further proceedings because the residual functional capacity limitation concerning high-quota production-rate work was inadequately defined, preventing meaningful judicial review and assessment of the vocational expert’s testimony.

Holdings

  1. The ALJ's decision was not supported by substantial evidence because the limitation against high-quota production-rate-pace jobs requiring strict hourly quotas was not clearly defined or adequately connected to the evidence.
  2. An agency decision must state its conclusions in terms that permit the reviewing court to understand and evaluate the evidentiary basis for those conclusions.

Questions Presented

  1. Whether the ALJ adequately explained the evidentiary basis for the RFC limitation barring high-quota production-rate-pace jobs requiring strict hourly quotas.
  2. Whether the undefined production-rate-pace limitation permitted meaningful judicial review and provided an adequate basis for the vocational expert's testimony.

Disposition

reversed_and_remanded

Cases Cited (15)

  • Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996)(followed)
  • Sims v. Apfel, 530 U.S. 103, 106-07 (2000)(followed)
  • Kiser v. Saul, 821 F. App'x 211, 212 (4th Cir. 2020)(followed)
  • Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012)(followed)
  • Coffman v. Bowen, 829 F.2d 514, 517 (4th Cir. 1987)(followed)
  • Laws v. Celebrezze, 368 F.2d 640, 642 (4th Cir. 1966)(followed)
  • Sterling Smokeless Coal Co. v. Akers, 131 F.3d 438, 439-40 (4th Cir. 1997)(followed)
  • DeLoatche v. Heckler, 715 F.2d 148, 150 (4th Cir. 1983)(followed)
  • Trena Sue Y. v. Kijakazi, No. DLB-20-1075, 2021 WL 4034264, at *2, *4 (D. Md. Sept. 3, 2021)(followed)
  • Biestek v. Berryhill, 587 U.S. 97, 102 (2019)(followed)

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