Mylindsie A. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Washington reversed the Commissioner of Social Security’s denial of supplemental security income and remanded the case for further administrative proceedings. The court held that outstanding issues remained concerning the evaluation of medical opinion evidence, substance-abuse materiality, symptom statements, daily activities, and vocational-expert testimony. The court declined to remand for an immediate award of benefits.

Holdings

1. The ALJ's decision was not supported by substantial evidence because the ALJ committed reversible error, including in evaluating Dr. Genthe's opinion. Reversal and remand under sentence four of 42 U.S.C. § 405(g) were therefore warranted.
2. Remand for an immediate award of benefits was inappropriate because outstanding issues and evidentiary conflicts remained for the ALJ to resolve.
3. On remand, if Plaintiff is found disabled, the ALJ must determine whether drug or alcohol addiction is a contributing factor material to the disability determination.
4. The ALJ must reconsider Dr. Genthe's opinion and the evidence, develop the record as needed, conduct a new sequential evaluation, and issue a new decision consistent with the order.

Questions Presented

1. Whether the ALJ's evaluation of the psychological opinion evidence and Plaintiff's symptom statements was reversible error.
2. Whether the case should be remanded for an immediate award of benefits under the credit-as-true rule or for further administrative proceedings.
3. What matters the ALJ must address on remand, including drug and alcohol addiction materiality, conflicts in the medical opinions, symptom waxing and waning, daily activities, and vocational-expert testimony.

Disposition

reversed_and_remanded