Mia Sharp Atherton v. Commissioner of the Social Security Administration

Summary

The United States District Court for the District of South Dakota reviewed the denial of Mia Sharp Atherton’s Social Security disability benefits. The court held that the Administrative Law Judge failed to properly account for Atherton’s cyclical vomiting syndrome, recent medical records, and statements from employers, coworkers, and her husband. The court granted Atherton’s motion, reversed the Commissioner’s decision, and remanded the case for rehearing under sentence four of 42 U.S.C. § 405(g).

Holdings

1. The ALJ's residual functional capacity finding was not supported by substantial evidence because it inadequately addressed the episodic nature and functional consequences of Atherton's cyclical vomiting syndrome and related gastrointestinal symptoms.
2. The ALJ failed to fully and fairly develop the record by not obtaining or considering relevant recent medical records and evidence from employers, a coworker, and Atherton's husband concerning the severity and vocational effects of her symptoms.
3. The case must be remanded to the Commissioner for rehearing consistent with the district court's decision.

Questions Presented

1. Whether the ALJ's residual functional capacity assessment was supported by substantial evidence when it did not adequately account for the episodic nature and functional effects of Atherton's cyclical vomiting syndrome.
2. Whether the ALJ failed to fully and fairly develop the record by failing to obtain or consider later medical records and third-party evidence concerning Atherton's symptoms and work limitations.
3. Whether the Appeals Council and the ALJ's treatment of the additional medical evidence required reversal and remand under sentence four of 42 U.S.C. § 405(g).

Disposition

reversed_and_remanded