Maria R. C. v. Commissioner of Social Security

Summary

The United States District Court for the District of New Jersey reviews the denial of Maria R. C.'s application for Disability Insurance Benefits under Title II of the Social Security Act. The court concludes that the Administrative Law Judge did not adequately explain consideration of the plaintiff's non-severe impairments in assessing her residual functional capacity. The Commissioner's decision is vacated and the matter is remanded for further consideration.

Holdings

1. An ALJ must consider both severe and non-severe medically determinable impairments when assessing a claimant's residual functional capacity; a finding that an impairment is non-severe cannot substitute for an RFC analysis of that impairment.
2. An ALJ must explain the reasoning underlying the RFC determination sufficiently to permit meaningful judicial review, although the ALJ need not use particular language or conduct an explicit function-by-function analysis when the reasoning is otherwise apparent from the decision as a whole.
3. Any alleged error in classifying additional impairments as non-severe was harmless because the ALJ proceeded beyond step two and found in Plaintiff's favor at that step.

Questions Presented

1. Whether the ALJ's residual-functional-capacity assessment was supported by substantial evidence and adequately explained.
2. Whether the ALJ was required to consider Plaintiff's non-severe medically determinable impairments in assessing her residual functional capacity.
3. Whether the alleged errors in the ALJ's step-two severity findings required reversal.

Disposition

reversed_and_remanded