Kelvin Fraser v. Frank Bisignano, Commissioner, Social Security Administration

Civil No. CJC-24-3018 (D. Md. Mar. 13, 2026) · United States District Court for the District of Maryland · March 13, 2026 · No. CJC-24-3018

Summary

The United States District Court for the District of Maryland reviews Kelvin Fraser’s challenge to the Social Security Administration’s denial of disability insurance benefits. The court holds that the Administrative Law Judge inadequately explained the evidentiary basis for the specific sit-stand-walk position changes included in Fraser’s residual functional capacity. Pursuant to sentence four of 42 U.S.C. § 405(g), the court reverses the Commissioner’s decision and remands for further proceedings.

Court
United States District Court for the District of Maryland
Jurisdiction
United States District Court for the District of Maryland
Decision date
March 13, 2026
Docket number
CJC-24-3018
Disposition
reversed_and_remanded

Questions Presented

  1. Whether the ALJ adequately explained the evidentiary basis for the RFC requirement allowing Fraser to change positions for up to five minutes every hour.
  2. Whether the ALJ's failure to provide a logical bridge between the evidence and the specific position-change intervals required reversal and remand.

Holdings

  1. The ALJ failed to adequately explain the basis for requiring Fraser to change positions for up to five minutes every hour. The decision's statement that the changes were needed to relieve pain or discomfort did not explain why those particular time intervals were supported by the medical evidence or other evidence in the record.

Court Document

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