Jennifer Smith v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Maryland reviewed Jennifer Smith’s claims for disability insurance benefits and supplemental security income. The court held that the Administrative Law Judge improperly evaluated Smith’s subjective symptoms by relying on objective medical evidence, failing to address material evidence, and inadequately assessing her daily activities. The court reversed the Commissioner’s decision and remanded the case for further proceedings under sentence four of 42 U.S.C. § 405(g).

Holdings

1. When a claimant has major depressive disorder, the ALJ may not rely on objective medical evidence, even as one of multiple factors, to discount the claimant's subjective complaints concerning the intensity and persistence of symptoms. The ALJ violated that rule by relying on normal or near-normal thought processes, thought content, memory, orientation, insight, and judgment to discount Smith's complaints.
2. An ALJ must adequately discuss material evidence concerning the intensity and persistence of a claimant's symptoms and explain how material inconsistencies or ambiguities were considered and resolved. The ALJ's failure to address significant contrary subjective evidence prevented meaningful judicial review and required remand.
3. When evaluating daily activities, an ALJ must consider the extent to which the claimant can perform those activities and must explain how the activities demonstrate an ability to sustain a full-time, 40-hour work week. The ALJ failed both requirements here.

Questions Presented

1. Whether the ALJ improperly relied on objective medical evidence to discount Smith's subjective complaints concerning symptoms of major depressive disorder.
2. Whether the ALJ adequately explained the intensity and persistence of Smith's symptoms and resolved material inconsistencies and ambiguities in the record.
3. Whether the ALJ properly considered the extent of Smith's daily activities and explained how those activities demonstrated an ability to sustain full-time work.

Disposition

reversed_and_remanded