Katana B. v. Frank Bisignano, Commissioner, Social Security Administration

Summary

The United States District Court for the District of Rhode Island reviews the denial of Katana B.'s claim for Supplemental Security Income. The court holds that the ALJ's residual functional capacity finding was not supported by substantial evidence because the state agency consultants lacked access to the complete medical record and the ALJ improperly reconciled later-produced evidence. The court grants the plaintiff's motion, denies the Commissioner's motion, and remands for further proceedings.

Holdings

1. The RFC was not supported by substantial evidence because the ALJ relied on state agency consultants' opinions that were formed without access to more than one hundred pages of relevant treating-therapist records.
2. The ALJ improperly substituted her own judgment for medical opinion by concluding that later-produced treating-therapist records were consistent with the consultants' opinions even though the consultants had not reviewed those records.
3. The ALJ erred in discounting Katana's statements based on activities such as writing, reading, playing board games, walking her dog, and performing light household chores, because those activities did not adequately contradict her reported difficulty functioning outside the home.

Questions Presented

1. Whether the ALJ adequately considered Katana's ability to sustain work over a normal workday and workweek.
2. Whether the ALJ's residual functional capacity assessment was supported by substantial evidence when the state agency consultants lacked the treating therapist's records.
3. Whether the ALJ improperly relied on a post hoc rationalization to reconcile later-produced medical evidence with the state agency consultants' opinions.
4. Whether the ALJ improperly discounted Katana's subjective statements based on limited activities performed inside or near her home.
5. Whether the Commissioner's Step Five analysis was legally and evidentially sufficient.

Disposition

reversed_and_remanded