Kelli S. v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Michigan reviewed the Commissioner of Social Security’s denial of Kelli S.’s applications for Disability Insurance Benefits and Supplemental Security Income. The court held that the Administrative Law Judge inadequately explained the supportability and consistency analysis applied to a consultative psychologist’s medical opinion. It denied the Commissioner’s motion, granted the plaintiff’s motion, and remanded the case for further proceedings under sentence four of 42 U.S.C. § 405(g).

Holdings

1. The ALJ did not adequately explain the supportability and consistency factors applicable to Dr. Brady's opinion. The ALJ's brief statement that Plaintiff interacted appropriately with treatment providers and examiners addressed, at most, social interaction and did not explain the treatment of Dr. Brady's findings concerning concentration, workplace stress, depression, or other functional limitations.
2. The Commissioner's decision that Plaintiff was not disabled was not supported by substantial evidence because the ALJ failed to provide a sufficient rationale for rejecting a medical opinion addressing a critical aspect of Plaintiff's disability claim.

Questions Presented

1. Whether the ALJ adequately explained the supportability and consistency analysis required by 20 C.F.R. §§ 404.1520c and 416.920c when discounting Dr. Brady's medical opinion.
2. Whether the ALJ's finding that Plaintiff was not disabled was supported by substantial evidence.
3. Whether remand under sentence four of 42 U.S.C. § 405(g) was required.

Disposition

reversed_and_remanded