Lori H-L. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the District of Minnesota remands a Social Security disability case for further consideration of the claimant’s residual functional capacity and subjective symptom statements. The court concludes that the Administrative Law Judge did not adequately address the claimant’s somatic symptom disorder or explain which subjective statements were inconsistent with the record. The court also directs reconsideration of whether the claimant’s headaches medically equal Listing 11.02.

Holdings

1. The ALJ's RFC analysis was insufficient because it did not adequately explain which of Plaintiff's subjective statements were inconsistent with which record evidence, did not explain the effect of her somatic symptom disorder on her perception of symptoms, and relied on inadequately characterized daily activities. Remand was required for further consideration under SSR 16-3p.
2. Because the RFC and subjective-symptom analysis required remand and the step-three analysis appeared to rely on the RFC formulation, the ALJ must reconsider whether Plaintiff's headache disorder meets or medically equals Listing 11.02. The court did not finally determine that Plaintiff satisfied the listing.
3. The court declined to decide the closed-period argument on the existing record, but instructed the ALJ to consider on remand whether any twelve-month period entitled Plaintiff to benefits.

Questions Presented

1. Whether the ALJ adequately evaluated Plaintiff's subjective symptoms and somatic symptom disorder in determining her residual functional capacity.
2. Whether the ALJ adequately considered whether Plaintiff's migraine or headache disorder medically equaled Listing 11.02.
3. Whether the case should be remanded for consideration of a closed period of disability.

Disposition

reversed_and_remanded