Lancaster v. Commissioner of Social Security

Summary

The magistrate judge recommends reversing the Commissioner of Social Security’s denial of Ferwilda Lancaster’s application for Supplemental Security Income and remanding for further proceedings. The court concludes that the administrative law judge failed to provide specific, clear, and convincing reasons for discounting Lancaster’s subjective symptom testimony concerning her migraine headaches. The recommendation directs entry of judgment for Lancaster, subject to the parties’ opportunity to file objections.

Holdings

1. Because the ALJ found that Plaintiff's medically determinable impairments could reasonably be expected to cause her alleged symptoms and there was no finding of malingering, the ALJ was required to provide specific, clear, and convincing reasons for rejecting the alleged severity of Plaintiff's migraine symptoms. The ALJ failed to do so.
2. The ALJ did not properly use Plaintiff's limited cooking, cleaning, shopping, and related daily activities to discount her migraine symptom testimony.
3. The ALJ did not properly rely on conservative or effective treatment as a basis for discounting Plaintiff's migraine symptom testimony.
4. Remand for further administrative proceedings was appropriate rather than an immediate award of benefits.

Questions Presented

1. Whether the ALJ provided legally sufficient reasons for discounting Lancaster's subjective symptom testimony concerning her migraine headaches.
2. Whether the ALJ's denial of Supplemental Security Income was supported by substantial evidence and based on proper legal standards.
3. Whether the appropriate remedy was remand for further administrative proceedings or an immediate award of benefits.

Disposition

reversed_and_remanded