Malcolm S. v. Frank Bisignano

Summary

The United States District Court for the District of New Mexico grants Plaintiff’s motion to reverse and remand a Social Security disability decision. The court holds that the administrative law judge inadequately assessed the opinions of three treating providers, particularly regarding Plaintiff’s limitations in standing, walking, sitting, and work-related functioning. The court remands for further proceedings and does not reach Plaintiff’s argument concerning whether his work constituted a trial work period.

Holdings

1. An ALJ must articulate how persuasive each medical opinion is and must explain consideration of the supportability and consistency factors; conclusory statements that an opinion is inconsistent with treatment records or work activity are legally insufficient.
2. The ALJ erred by rejecting the treating providers' limitations on Plaintiff's abilities to sit, stand, and walk without identifying and analyzing supporting record evidence.
3. The ALJ erred by treating limitations caused by pain and fatigue as psychological limitations and rejecting them solely by reference to mental-status examinations and work activity without explanation.
4. When an RFC assessment conflicts with a medical-source opinion, the ALJ must explain why the opinion was not adopted, including when the ALJ rejects less-than-occasional limitations in kneeling, stooping, crouching, and crawling in favor of occasional limitations.

Questions Presented

1. Whether the ALJ adequately evaluated and articulated the persuasiveness of the opinions of treating providers Bhalachandra Kulkarni, Tyler Owens, and Amanda Renfro under the applicable Social Security regulations.
2. Whether the ALJ adequately explained the rejection of the providers' limitations concerning sitting, standing, and walking.
3. Whether the ALJ adequately explained the rejection of limitations attributed to pain and fatigue, including limitations on attendance, concentration, work pace, and workplace interaction.
4. Whether the ALJ was required to explain the conflict between the providers' less-than-occasional postural limitations and the RFC finding that Plaintiff could occasionally kneel, stoop, crouch, and crawl.

Disposition

reversed_and_remanded