Jennifer L. E. v. Frank Bisignano, Commissioner of the Social Security Administration

Summary

The United States District Court for the District of New Mexico granted Plaintiff Jennifer L. E.’s motion to reverse and remand the Commissioner of Social Security’s denial of supplemental security income. The court held that the Administrative Law Judge failed to adequately consider Plaintiff’s diagnosed chronic pain syndrome, including its physical and psychological effects, when formulating her residual functional capacity. The case was remanded for further proceedings consistent with the opinion.

Holdings

1. The ALJ's failure to discuss whether chronic pain syndrome was severe or non-severe at step two was not reversible error because the ALJ found other severe impairments and proceeded to the next steps of the sequential evaluation.
2. The ALJ committed reversible legal error by failing to evaluate Plaintiff's diagnosed chronic pain syndrome as an impairment when formulating the RFC. The ALJ's general references to pain did not establish that he considered the distinct physical and psychological effects of chronic pain syndrome.
3. The court declined to address Plaintiff's remaining claims because chronic pain syndrome may affect the other determinations on remand.

Questions Presented

1. Whether the ALJ's failure to determine separately whether Plaintiff's chronic pain syndrome was severe or non-severe at step two constituted reversible error.
2. Whether the ALJ adequately considered Plaintiff's chronic pain syndrome, including its physical and psychological effects, when formulating the residual functional capacity.
3. Whether the court should address Plaintiff's remaining claims of error after finding reversible error in the RFC analysis.

Disposition

reversed_and_remanded