Benjamin G. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Pennsylvania reviewed the Commissioner of Social Security’s denial of Benjamin G.’s claim for Supplemental Security Income. The court granted Plaintiff’s Request for Review and remanded the matter for further administrative proceedings, following a prior remand concerning the evaluation of medical opinions and related evidence.

Holdings

1. The ALJ failed to adequately explain her evaluation of the supportability and consistency of Dr. Kaufman's opinion, particularly regarding Plaintiff's need for restroom access and additional breaks, and materially mischaracterized or selectively considered evidence concerning emergency-room visits, Remicade treatment, and Plaintiff's work activity.
2. The ALJ failed to resolve the inconsistency between finding that Plaintiff had no useful ability to complete a normal workday and workweek without interruptions from psychologically based symptoms and determining that Plaintiff could perform competitive work under the RFC.
3. Remand, rather than an immediate award of benefits, was the appropriate remedy because evidentiary questions remained and the outcome could change after proper evaluation of the medical opinions.

Questions Presented

1. Whether the ALJ adequately evaluated the supportability and consistency of Dr. Kaufman's medical opinions under 20 C.F.R. § 416.920c.
2. Whether the ALJ adequately evaluated Dr. DelBusto's opinion and resolved the inconsistency between crediting a limitation involving inability to complete a normal workday and the RFC finding that Plaintiff could perform competitive work.
3. Whether the court should reverse and award benefits or remand for further administrative proceedings.

Disposition

reversed_and_remanded