David B. v. Frank Bisignano, Commissioner of Social Security Administration

Summary

The United States District Court for the Eastern District of Missouri reviews the Social Security Administration’s denial of David B.’s application for disability insurance benefits. The court concludes that the ALJ did not adequately explain the consistency analysis concerning nurse practitioner Kacey Patterson’s medical opinion under 20 C.F.R. § 404.1520c. The court reverses the Commissioner’s denial and remands the case for further proceedings.

Holdings

1. The ALJ failed to adequately explain the consistency of NP Patterson's medical opinion with the longitudinal record because the ALJ relied on a conclusory statement and a string citation without identifying which records demonstrated improvement or stabilization or explaining how those records conflicted with the functional limitations Patterson identified.
2. The Commissioner's denial of Plaintiff's disability application must be reversed and the case remanded for reconsideration and further proceedings consistent with the opinion.

Questions Presented

1. Whether the ALJ adequately evaluated and explained the supportability and consistency of Nurse Practitioner Kacey Patterson's medical opinion under 20 C.F.R. § 404.1520c.
2. Whether substantial evidence supported the ALJ's residual functional capacity assessment and the Commissioner's denial of disability benefits.

Disposition

reversed_and_remanded