Melissa E. v. Frank Bisignano, Commissioner of Social Security Administration

Summary

The United States District Court for the District of Minnesota reviews the Commissioner of Social Security’s denial of Melissa E.’s application for Supplemental Security Income. The court finds that the ALJ properly evaluated Plaintiff’s subjective complaints but that the residual functional capacity did not clearly impose an aggregate limitation on standing and walking supported by the record. The court remands the matter under sentence four of 42 U.S.C. § 405(g) for further administrative proceedings.

Holdings

1. The ALJ did not err in evaluating and discounting Plaintiff's subjective complaints because the ALJ considered the record as a whole, including medication benefits, treatment history, physical-therapy participation, medical observations, and daily activities, and provided good reasons supported by substantial evidence.
2. The RFC was not supported by substantial evidence because it did not clearly reflect the record-supported limitation on Plaintiff's combined standing and walking, and instead could be read to permit standing and walking throughout the entire workday subject only to separate continuous-duration limits.
3. An ALJ may not rely on vocational-expert testimony that appears to conflict with a Dictionary of Occupational Titles listing without identifying and resolving the conflict; unresolved testimony is not substantial evidence supporting denial of benefits.

Questions Presented

1. Whether the ALJ properly evaluated Plaintiff's subjective complaints of pain and other symptoms under the applicable regulatory and Polaski-factor framework.
2. Whether substantial evidence supported the RFC where it separately limited standing and walking but did not clearly impose the aggregate standing-and-walking limitation supported by the medical-expert testimony.
3. Whether the ALJ was required to identify and resolve the apparent conflict between the vocational expert's testimony and the Dictionary of Occupational Titles regarding the standing-and-walking requirements of the representative occupations.
4. Whether the RFC and unresolved vocational conflict constituted harmful error requiring remand.

Disposition

reversed_and_remanded