Diane A. Heskett v. Frank Bisignano, Commissioner of Social Security

Summary

The court reviewed the Commissioner of Social Security’s denial of Diane A. Heskett’s application for disability insurance benefits. It held that the ALJ failed to adequately develop the record and that the physical residual functional capacity determination was not supported by substantial evidence after the ALJ rejected the medical opinions in the record. The court found the error harmful and ordered remand for further proceedings.

Holdings

1. The ALJ's physical RFC determination was not supported by substantial evidence because the ALJ rejected all medical opinions concerning Plaintiff's functional limitations and formulated specific work restrictions from the ALJ's own interpretation of raw medical evidence and testimony.
2. The ALJ had a duty to further develop the record because the treatment and imaging evidence was raw and ambiguous regarding the functional limitations caused by Plaintiff's impairments.
3. The error was harmful because a properly developed record and different RFC limitations could have changed the disability determination and the vocational expert's testimony was based on incomplete hypotheticals.
4. The court declined to reach Plaintiff's alternative challenge to the ALJ's evaluation of her subjective symptom complaints because remand was independently required for further development of the record.

Questions Presented

1. Whether the ALJ's physical RFC determination was supported by substantial evidence when the ALJ rejected every medical opinion concerning Plaintiff's functional limitations and independently translated raw medical evidence into work restrictions.
2. Whether the ALJ had a duty to further develop the administrative record because the evidence concerning Plaintiff's functional limitations was ambiguous or inadequate.
3. Whether the ALJ's error was harmful and required remand.
4. Whether the ALJ provided legally sufficient reasons for rejecting Plaintiff's subjective symptom complaints.

Disposition

vacated