Kelvin W. v. Commissioner of Social Security Administration

Kelvin W. · United States District Court for the District of South Carolina · April 20, 2026 · No. 0:25-2948-RMG-PJG

Summary

This Report and Recommendation addresses Kelvin W.’s appeal from the Commissioner of Social Security’s denial of Social Security benefits. The magistrate judge recommends reversal and remand under sentence four of 42 U.S.C. § 405(g), concluding that the ALJ inadequately explained the residual functional capacity assessment, particularly regarding concentration, persistence, and pace.

Holdings

  1. The ALJ failed to sufficiently explain how the RFC accounted for the plaintiff's accepted moderate limitations in concentration, persistence, or pace, and the internal inconsistencies in the RFC analysis frustrated meaningful judicial review.
  2. Reversal and remand under sentence four of 42 U.S.C. § 405(g) was warranted for further consideration of the plaintiff's RFC.

Questions Presented

  1. Whether the ALJ's RFC assessment adequately accounted for the plaintiff's moderate limitation in concentration, persistence, or pace.
  2. Whether the ALJ sufficiently explained the relationship between the evidence, the RFC limitations, and the vocational expert's testimony.
  3. Whether the ALJ's hypothetical to the vocational expert omitted limitations that required remand.

Disposition

reversed_and_remanded

Cases Cited (24)

  • Blalock v. Richardson, 483 F.2d 773 (4th Cir. 1973)(followed)
  • McLain v. Schweiker, 715 F.2d 866, 868-69 (4th Cir. 1983)(followed)
  • Hall v. Harris, 658 F.2d 260, 264-65 (4th Cir. 1981)(followed)
  • Wilson v. Califano, 617 F.2d 1050, 1053 (4th Cir. 1980)(followed)
  • Grant v. Schweiker, 699 F.2d 189, 192 (4th Cir. 1983)(followed)
  • Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996)(followed)
  • Coffman v. Bowen, 829 F.2d 514, 517 (4th Cir. 1987)(followed)
  • Brown v. Commissioner of Social Security Administration, 873 F.3d 251, 267 (4th Cir. 2017)(followed)
  • Myers v. Califano, 611 F.2d 980, 982 (4th Cir. 1980)(followed)
  • Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019)(followed)

Showing top 10 of 24.

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