Mary S. v. Commissioner of Social Security

Summary

The Eastern District of Michigan reviewed the Commissioner of Social Security’s denial of Mary S.’s application for disability insurance benefits. The court held that the ALJ inadequately explained the supportability and consistency analyses applied to the opinions of consultative examiner Terry Rudolph, Ph.D., and treating physician Jack Parent, M.D. The court granted Plaintiff’s motion for summary judgment in part, denied the Commissioner’s motion, and remanded for further proceedings.

Holdings

1. The ALJ did not adequately explain the supportability and consistency factors when discounting Dr. Rudolph's opinion, particularly the asserted inconsistency between Plaintiff's inability to interact with supervisors and her need for frequent supervision and feedback.
2. The ALJ did not adequately explain the supportability and consistency factors when discounting Dr. Parent's opinion concerning migraine-related limitations.
3. Remand was required because the ALJ's inadequate explanation may have prejudiced Plaintiff and prevented meaningful judicial review.

Questions Presented

1. Whether the ALJ adequately evaluated the supportability and consistency of Dr. Rudolph's psychological opinion under 20 C.F.R. § 404.1520c.
2. Whether the ALJ adequately evaluated the supportability and consistency of Dr. Parent's opinion concerning the functional effects of Plaintiff's migraines under 20 C.F.R. § 404.1520c.
3. Whether the ALJ's inadequate articulation prejudiced Plaintiff and required remand for further administrative proceedings.

Disposition

remanded