Summary
The United States District Court for the District of Utah reviews the denial of Joseph W.'s claim for Social Security Disability Insurance benefits. The court holds that the Administrative Law Judge failed to explain why he accepted some of Dr. Thomas L. Lombardi's medical-opinion restrictions while rejecting others. The court reverses the Commissioner's decision and remands for further proceedings.
Holdings
- When an ALJ affords at least some weight to a medical source's opinion, the ALJ must explain why the ALJ accepted some recommendations while rejecting others. Failure to provide that explanation is legal error.
- The error was harmful because the unexplained restrictions went to the heart of the RFC determination and could affect whether Plaintiff could perform jobs in the national economy.
Questions Presented
- Whether the ALJ erred by failing to explain why he accepted some portions of Dr. Lombardi's partially persuasive medical opinion while rejecting or failing to address other portions.
- Whether that error was harmful and required reversal and remand of the Commissioner's decision.
Disposition
reversed_and_remanded
Cases Cited (8)
- Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007)(followed)
- Madrid v. Barnhart, 447 F.3d 788, 790 (10th Cir. 2006)(followed)
- Jensen v. Barnhart, 436 F.3d 1163, 1165 (10th Cir. 2005)(followed)
- Williams v. Bowen, 844 F.2d 748, 750-51 (10th Cir. 1988)(followed)
- Haga v. Astrue, 482 F.3d 1205, 1208-09 (10th Cir. 2007)(followed)
- Benavidez v. Colvin, 650 F. App'x 619, 621-22 (10th Cir. 2016)(followed)
- Lopez v. Colvin, 642 F. App'x 826, 829 (10th Cir. 2016)(followed)
- Allen v. Barnhart, 357 F.3d 1140, 1145 (10th Cir. 2004)(followed)
Cited In (0)
No citing cases on record yet.
Court Document
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