Heath Dawson v. Frank Bisignano, Commissioner, Social Security Administration

Summary

The United States District Court for the District of Maryland reviews the Social Security Administration's denial of Heath Dawson's application for supplemental security income. The court holds that the administrative law judge failed to adequately explain the specific sit/stand intervals included in Dawson's residual functional capacity assessment. 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. The ALJ failed to provide an adequate explanation connecting the medical and other evidence to the specific conclusion that Dawson needed to change positions for one to two minutes every thirty minutes.
2. Remand was appropriate because inadequacies in the ALJ's analysis frustrated the court's ability to determine whether the decision was supported by substantial evidence.

Questions Presented

1. Whether the ALJ adequately explained the RFC limitation requiring Dawson to change positions for one to two minutes every thirty minutes.
2. Whether the Commissioner's final decision was supported by substantial evidence and reached through application of the correct legal standard.

Disposition

reversed_and_remanded