Amanda Styles v. Frank Bisignano, Commissioner of Social Security Administration

Summary

The document is a Report and Recommendation in Amanda Styles’s Social Security disability action against the Commissioner of Social Security. The magistrate judge concluded that the ALJ did not adequately explain or resolve the evidence concerning Styles’s need to elevate her legs, preventing meaningful judicial review of the residual functional capacity determination. The recommendation is to reverse the Commissioner’s decision and remand the matter for further proceedings under sentence four of 42 U.S.C. § 405(g).

Holdings

1. The ALJ's decision cannot be meaningfully reviewed because it acknowledged evidence of swelling, edema, and Styles's testimony regarding leg elevation but did not explain whether that evidence supported a functional limitation or resolve the issue's potential effect on her ability to work.
2. The ALJ, rather than a medical source, is responsible for formulating the RFC from the entire evidentiary record, and an opinion specifically quantifying the elevation limitation is not required; however, the ALJ must still explain and resolve the relevant evidence.

Questions Presented

1. Whether the ALJ's residual-functional-capacity assessment was supported by substantial evidence and adequately explained the evidence concerning Styles's alleged need to elevate her legs.
2. Whether the case should be remanded because the ALJ failed to resolve material inconsistencies or ambiguities concerning the frequency and height of leg elevation and its effect on the occupational base.

Disposition

reversed_and_remanded