Cruz v. Commissioner of Social Security

Summary

The document contains findings and recommendations in Ronnie Cruz’s action seeking judicial review of the Commissioner of Social Security’s denial of disability insurance benefits. The magistrate judge recommends granting Cruz’s motion for summary judgment and remanding under sentence four of 42 U.S.C. § 405(g) for further proceedings, including evaluation of Listing 2.02 and reconsideration of the residual functional capacity. The recommendations identify deficiencies in the ALJ’s treatment of worsening vision and foot impairments.

Holdings

1. The ALJ's step-three analysis was inadequate because it omitted and did not evaluate the November 2022 finding of 20/400 vision with no improvement from pinhole correction, leaving unresolved whether Cruz's best corrected visual acuity in the better eye satisfied Listing 2.02.
2. The RFC finding was not supported by substantial evidence because the ALJ recognized worsening vision and foot conditions yet imposed only a depth-perception limitation and no limitation on standing or walking, despite evidence potentially inconsistent with those findings.
3. Remand was appropriate for the ALJ to obtain medical opinion evidence concerning Cruz's best corrected visual acuity and to reconsider the impact of the visual and foot impairments on the RFC.

Questions Presented

1. Whether the ALJ adequately evaluated whether Cruz's visual impairment met or medically equaled Listing 2.02 for loss of central visual acuity.
2. Whether the ALJ's residual functional capacity finding was supported by substantial evidence in light of worsening vision, foot ulcers, and advice to limit standing and walking.
3. Whether the ALJ was required to further develop the record by obtaining updated medical opinion evidence regarding Cruz's visual acuity and functional limitations.

Disposition

remanded