Richard Williams v. Frank Bisignano, Commissioner of Social Security

Summary

This Memorandum and Recommendation addresses Richard Williams’s action seeking judicial review of the denial of Social Security disability insurance benefits. The magistrate judge recommends allowing Plaintiff’s brief and remanding the matter to the Commissioner for further proceedings because the ALJ did not adequately address evidence suggesting a possible mental impairment or apply the required special technique. The document is from the United States District Court for the Eastern District of North Carolina.

Holdings

1. The ALJ was required to address the medical-record references to adjustment-disorder-spectrum symptoms and cognitive difficulties because they constituted contradictory evidence to the ALJ’s finding that the record contained no evidence of a psychiatric impairment.
2. Where the record raises a colorable claim of a mental impairment, the ALJ must evaluate the pertinent symptoms, signs, and laboratory findings under the regulatory special technique and adequately document the resulting findings.
3. The Commissioner may not sustain the ALJ’s decision through post-hoc reasoning that the ALJ did not provide, and reliance on state-agency psychological opinions did not cure the ALJ’s failure to analyze the relevant mental-health evidence.

Questions Presented

1. Whether the ALJ adequately considered evidence suggesting that Williams had a medically determinable mental impairment.
2. Whether the ALJ was required to apply and document the regulatory special technique for evaluating mental impairments.
3. Whether the ALJ’s failure to discuss contradictory evidence prevented meaningful judicial review and required remand.

Disposition

remanded