Steven S. v. Frank Bisignano, Commissioner, Social Security Administration

Summary

The United States District Court for the District of Maryland remands a Social Security disability case for further consideration. The court concludes that the Administrative Law Judge improperly discounted the claimant’s depressive symptoms based on objective medical findings and improperly relied on work history before and after the claimed closed period of disability.

Holdings

1. The ALJ committed legal error by relying on objective medical evidence, including generally normal mental-status findings, to discount Plaintiff's subjective symptoms of depression after finding that depression was a medically determinable severe impairment.
2. The ALJ improperly relied on Plaintiff's employment before and after the closed period to discount his allegations without explaining how that work demonstrated an ability to work during the closed period.

Questions Presented

1. Whether the ALJ improperly discounted the intensity, persistence, and limiting effects of Plaintiff's depressive symptoms by relying on objective medical findings.
2. Whether the ALJ improperly relied on Plaintiff's work history before and after the closed period to assess his ability to work during the closed period.

Disposition

reversed_and_remanded