Tracey Lynn Anderson v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of California reviewed a Social Security disability benefits decision involving right ulnar neuropathy. The court held that the Administrative Law Judge failed to determine whether the neuropathy was a severe impairment and failed to adequately account for it in the residual functional capacity assessment. The Commissioner’s decision was reversed and remanded for further administrative proceedings.

Holdings

1. The medical evidence established that Plaintiff had a medically determinable impairment of right ulnar neuropathy before the ALJ hearing.
2. The ALJ committed reversible error by failing to consider whether right ulnar neuropathy was a severe impairment at step two and by failing to consider the impairment at subsequent steps, including whether it affected the listings analysis and the RFC.
3. Remand for further administrative proceedings, rather than immediate payment of benefits, was appropriate.

Questions Presented

1. Whether the ALJ erred by failing to determine at step two whether Plaintiff's medically determinable right ulnar neuropathy was a severe impairment.
2. Whether the ALJ adequately considered right ulnar neuropathy at subsequent steps, including the listings analysis and residual functional capacity assessment.
3. Whether the case should be remanded for immediate payment of benefits or for further administrative proceedings.

Disposition

reversed_and_remanded