Kanan C. v. Frank Bisignano, Commissioner, Social Security Administration

Summary

The District of Maryland reversed the Commissioner of Social Security’s denial of Kanan C.’s claims for Disability Insurance Benefits and Supplemental Security Income and remanded for further proceedings. The court held that the Administrative Law Judge inadequately analyzed the supportability of an October 2022 neuropsychological evaluation under 20 C.F.R. § 404.1520c. The court did not address the plaintiff’s remaining arguments and directed that the case be closed.

Holdings

1. The ALJ did not adequately evaluate the supportability factor because the decision did not explain whether the objective medical evidence, diagnostic techniques, and supporting explanations presented by the providers supported their opinions.
2. The inadequate supportability analysis was potentially consequential because a properly evaluated opinion could have changed the weight assigned to the October 2022 evaluation, the RFC, and the disability determination.
3. The court did not need to resolve Plaintiff's other arguments because remand was required on the inadequate supportability analysis.

Questions Presented

1. Whether the ALJ adequately evaluated the supportability of the October 2022 neuropsychological evaluation under 20 C.F.R. § 404.1520c(c)(1).
2. Whether the ALJ's failure to adequately analyze the evaluation was consequential because the opinion could have affected Plaintiff's RFC and the vocational determination.
3. Whether the court should address Plaintiff's additional arguments concerning the RFC and evaluation of the opinion evidence.

Disposition

reversed_and_remanded