Seamus H. v. Frank Bisignano, Commissioner of Social Security

Summary

The document addresses a claimant’s challenge to the Commissioner of Social Security’s denial of Child Disability Benefits and Supplemental Security Income. The court concludes that the Administrative Law Judge’s decision is not supported by substantial evidence and recommends remand for further proceedings under sentence four of 42 U.S.C. § 405(g).

Holdings

1. The ALJ's rejection of substantial portions of the treating nurse practitioner's opinion was not supported by substantial evidence because the ALJ misread and mischaracterized material treatment records, including mental-status examinations and the reasons Plaintiff was not pursuing remote work.
2. The Commissioner's decision was not supported by substantial evidence because the ALJ's errors in characterizing the treatment record undermined the evaluation of Plaintiff's impairments, medical opinions, testimony, third-party evidence, and RFC.

Questions Presented

1. Whether the ALJ's evaluation of the treating nurse practitioner's medical-source opinion was supported by substantial evidence.
2. Whether the ALJ improperly mischaracterized or selectively considered the mental-health treatment records in assessing the RFC.
3. Whether the ALJ's evaluation of Plaintiff's subjective complaints and his mother's third-party statement was affected by the same errors.
4. Whether the ALJ adequately considered agoraphobia and its limitations at step two, in evaluating the Listings, and in formulating the RFC.

Disposition

remanded