Jonathan W. v. Bisignano, Commissioner of the Social Security Administration

Summary

The United States District Court for the District of Maryland reviewed the Social Security Administration’s denial of Jonathan W.’s applications for disability insurance benefits and supplemental security income. The court held that the Administrative Law Judge inadequately analyzed the claimant’s residual functional capacity, particularly the impact of severe migraine or tension headaches on sustained work, absenteeism, and productivity. The court reversed the Commissioner’s decision in part and remanded for further administrative proceedings under sentence four of 42 U.S.C. § 405(g).

Holdings

1. The ALJ erred by failing to make explicit findings regarding Plaintiff's ability to sit, stand, walk, lift, and carry, and by determining that Plaintiff could perform light work before performing the required function-by-function analysis.
2. The ALJ erred by failing to explain how the frequency and duration of Plaintiff's severe headaches affected his ability to perform sustained work, including whether they would cause absenteeism, frequent breaks, or decreased productivity.

Questions Presented

1. Whether the ALJ adequately assessed Plaintiff's residual functional capacity under SSR 96-8p and applicable regulations.
2. Whether the ALJ adequately explained how Plaintiff's severe migraine or tension headaches affected his ability to perform sustained work, including potential absenteeism, breaks, and decreased productivity.
3. Whether the ALJ properly evaluated Plaintiff's subjective complaints and the medical opinions.

Disposition

reversed_and_remanded