Tiyana M. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Pennsylvania reviews the Commissioner of Social Security’s denial of Tiyana M.’s claims for Disability Insurance Benefits and Supplemental Security Income. The court recommends granting the request for review in part and remanding for evaluation by a rheumatologist of medical records concerning fibromyalgia and related autoimmune conditions. It also directs reevaluation of the claimant’s subjective symptom statements in light of the new medical opinion evidence.

Holdings

1. The ALJ's assessment of Nurse Slade's opinion was not supported by substantial evidence because the ALJ dismissed limitations based largely on painful trigger points and largely normal examination findings without adequately addressing the opinion's consistency with the medical record or identifying specific contradictory treatment records.
2. The matter must be remanded to the agency for review of the relevant medical records by a rheumatologist and for a supplemental or amended ALJ decision addressing the claimant's functioning during the relevant period.
3. On remand, the ALJ should reevaluate Tiyana M.'s subjective claims in light of the new medical opinion evidence obtained from a rheumatologist.

Questions Presented

1. Whether the ALJ properly evaluated the supportability and consistency of the consulting examiner's opinion concerning functional limitations caused by fibromyalgia.
2. Whether the ALJ's reliance on largely normal clinical findings and the absence of cited contradictory treatment records was supported by substantial evidence.
3. Whether the claimant's subjective reports should be reevaluated in light of additional medical opinion evidence on remand.

Disposition

remanded