Gonzalez v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of California recommends granting Briana Monserat Gonzalez’s motion for summary judgment and remanding her supplemental security income disability claim for further proceedings. The court concludes that the ALJ failed to adequately evaluate treating source Dr. Bahter’s opinion and did not sufficiently explain the findings concerning concentration and social functioning. The recommendation calls for a sentence-four remand under 42 U.S.C. § 405(g) and entry of judgment in favor of Plaintiff.

Holdings

1. The ALJ failed to adequately evaluate the supportability and consistency of Dr. Bahter's opinion concerning plaintiff's concentration and social-functioning limitations because the ALJ did not meaningfully address supporting examination findings and did not make the analytical path discernible.
2. Substantial evidence and applicable law did not support the ALJ's conclusion that plaintiff was not disabled; remand for further proceedings was warranted.

Questions Presented

1. Whether the ALJ properly evaluated Dr. Bahter's medical opinion concerning plaintiff's concentration and social-functioning limitations under the applicable medical-opinion regulations.
2. Whether substantial evidence supported the ALJ's mental residual functional capacity finding and resulting conclusion that plaintiff was not disabled.

Disposition

remanded