Sergio G. v. Frank Bisignano

Summary

The United States District Court for the District of New Jersey reviews Sergio G.’s appeal from the Commissioner of Social Security’s denial of Disability Insurance Benefits and Supplemental Security Income. The court concludes that the administrative law judge failed to address conflicting evidence regarding whether Plaintiff had earned an associate degree, despite relying on that point in evaluating the listings and residual functional capacity. The court reverses the Commissioner’s decision and remands for further proceedings.

Holdings

1. The ALJ's paragraph B findings could not be upheld because the ALJ relied on Plaintiff's purported associate's degree but failed to acknowledge or resolve Plaintiff's contrary hearing testimony that he had completed only high school.
2. The RFC determination could not be upheld because the ALJ relied on the same unexplained and potentially erroneous educational-attainment finding when crafting the RFC.
3. The Commissioner's decision was reversed and the matter remanded for further proceedings consistent with the opinion.

Questions Presented

1. Whether the ALJ's paragraph B findings at step three were supported by substantial evidence and adequately explained when the ALJ relied on Plaintiff's purported associate's degree without addressing his testimony that he completed only high school.
2. Whether the ALJ's residual functional capacity determination at step four was supported by substantial evidence and adequate reasoning.
3. Whether remand was required for further proceedings because the ALJ failed to resolve a material evidentiary conflict and provide a logical explanation permitting meaningful judicial review.

Disposition

reversed_and_remanded