Anita J. Burton v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Tennessee reviews a Social Security disability determination under 42 U.S.C. § 405(g). The court holds that the administrative law judge inadequately explained the standing and walking limitations adopted in the residual functional capacity assessment and failed to address a consultative examiner’s sitting limitation. The matter is remanded under sentence four of § 405(g) for further proceedings and a new decision.

Holdings

1. The ALJ's statement that he selected a midpoint between conflicting medical opinions did not adequately explain why the adopted two-to-four-hour standing and walking limitation accurately reflected Burton's functional capacity.
2. The ALJ erred by failing to state whether he considered the consultative examiner's opinion that Burton could sit only four to six hours in an eight-hour workday and, if considered, why he rejected that limitation.
3. Remand to the Commissioner was required because the ALJ failed to conform to the relevant legal standards when explaining Burton's residual functional capacity.

Questions Presented

1. Whether the ALJ adequately explained the basis for limiting Burton's standing and walking to two to four hours in an eight-hour workday.
2. Whether the ALJ adequately addressed the consultative examiner's opinion that Burton was limited to four to six hours of sitting in an eight-hour workday.
3. Whether the ALJ's failure to explain the adopted residual-functional-capacity limitations required remand under 42 U.S.C. § 405(g).

Disposition

remanded