Staci R. v. Commissioner, Social Security Administration

Summary

The United States District Court for the District of Oregon reviewed the Commissioner of Social Security’s denial of disability benefits for the period before December 5, 2014. The court held that the Administrative Law Judge improperly assigned no weight to the testimony of the medical expert concerning the claimant’s mental limitations and need for unscheduled breaks. The court reversed the Commissioner’s decision and remanded for calculation and payment of benefits.

Holdings

1. The ALJ erred by assigning no weight to the medical expert's opinion based on the terminology he used and by treating the opinion as internally inconsistent. The expert's use of "marked" and "seriously limited" was consistent with the Social Security regulations, and a marked limitation allowing some contact with others was not inherently inconsistent with a marked, rather than extreme, social limitation.
2. The ALJ erred by assigning no weight to the medical expert's opinion that Plaintiff required reasonable accommodations in the form of unscheduled breaks when panic attacks occurred.
3. The ALJ's error was harmful because crediting the medical expert's opinion established that Plaintiff required additional unscheduled breaks that would preclude competitive full-time employment.
4. Remand for calculation and payment of benefits was appropriate because the record was fully developed, the ALJ failed to provide legally sufficient reasons for rejecting the medical expert's opinion, crediting that opinion as true required a finding of disability, and the record created no serious doubt that Plaintiff was disabled.

Questions Presented

1. Whether the ALJ provided legally sufficient reasons supported by substantial evidence for assigning no weight to the testifying medical expert's opinion.
2. Whether the ALJ's rejection of the medical expert's testimony was harmful error.
3. Whether the credit-as-true standard was satisfied such that remand for calculation and payment of benefits, rather than further administrative proceedings, was warranted.

Disposition

reversed_and_remanded