Regina C. v. Frank Bisignano

Summary

The United States District Court for the Eastern District of Washington reversed the Social Security Administration ALJ’s denial of supplemental security income benefits to Plaintiff Regina C. The court held that the ALJ failed to adequately develop the medical record concerning Plaintiff’s congenital bilateral forearm deformity, including recommended imaging and orthopedic consultation. The case was remanded for further proceedings under sentence four of 42 U.S.C. § 405(g).

Holdings

1. The ALJ failed to develop the record, and that failure was consequential because the evidence was insufficient to determine the functional limitations caused by Plaintiff's congenital bilateral forearm deformity.
2. The challenge to the ALJ's evaluation of Plaintiff's subjective complaints was moot because remand for development of the medical record would require the ALJ to reconsider the medical opinions and Plaintiff's subjective complaints.
3. Further proceedings, rather than an immediate award of benefits, were appropriate because it was unclear what additional limitations should be included in the RFC.

Questions Presented

1. Whether the ALJ failed to discharge the duty to fully and fairly develop the medical record before evaluating Plaintiff's functional limitations and formulating the RFC.
2. Whether the ALJ improperly evaluated Plaintiff's subjective complaints.
3. Whether the ALJ's step-five finding was supported by substantial evidence.

Disposition

reversed_and_remanded