Melody K. v. Bisignano, Commissioner of the Social Security Administration

Melody K. · United States District Court for the District of Maryland · March 2, 2026 · No. Civil No. GLS-25-00416

Summary

The United States District Court for the District of Maryland reviews the Social Security Administration’s denial of disability benefits to Melody K. for the period before August 30, 2022. The court holds that the administrative law judge failed to provide an adequate narrative explanation linking the evidence to the residual functional capacity determination, including the 15-percent off-task limitation and the assessment of daily activities. The court reverses the agency’s decision in part and remands for further proceedings under sentence four of 42 U.S.C. § 405(g).

Holdings

  1. An ALJ's RFC finding must be accompanied by a narrative discussion describing the evidence supporting the finding, the logical explanation connecting the evidence to the finding, and the resulting conclusion. The ALJ failed to provide that explanation for both the absence of an off-task limitation before August 30, 2022 and the 15-percent-or-more off-task limitation beginning on that date.

Questions Presented

  1. Whether substantial evidence and proper legal standards supported the ALJ's RFC finding that Plaintiff had no off-task limitation before August 30, 2022.
  2. Whether the ALJ adequately explained and supported the 15-percent-or-more off-task limitation assigned beginning August 30, 2022.
  3. Whether the ALJ adequately connected Plaintiff's reported daily activities to the conclusion that she could sustain light work without an off-task limitation before August 30, 2022.

Disposition

reversed_and_remanded

Cases Cited (18)

  • Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996)(followed)
  • Barnhart v. Thomas, 540 U.S. 20, 24-25 (2003)(followed)
  • Mascio v. Colvin, 780 F.3d 632, 634-35 (4th Cir. 2015)(followed)
  • Bowen v. Yuckert, 482 U.S. 137, 140-42 (1987)(followed)
  • Monroe v. Colvin, 826 F.3d 176, 179-80, 189, 191 (4th Cir. 2016)(followed)
  • Hunter v. Sullivan, 993 F.2d 31, 35 (4th Cir. 1992) (per curiam)(followed)
  • Dowling v. Comm'r, Soc. Sec. Admin., 986 F.3d 377, 387-88 (4th Cir. 2021)(followed)
  • Thomas v. Berryhill, 916 F.3d 307, 311 (4th Cir. 2019)(followed)
  • Kane v. Comm'r, Soc. Sec. Admin., Civ. No. SAG 17-01252, 2018 WL 2739961, at *2 n.2 (D. Md. May 14, 2018)(followed)
  • Lee v. Berryhill, Civ. No. TMD 15-3307, 2017 WL 3007068, at *8 (D. Md. July 14, 2017)(followed)

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