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

Summary

The United States District Court for the Eastern District of Washington reverses the Administrative Law Judge’s denial of Social Security disability benefits to Plaintiff Victoria M. The court finds consequential errors in the evaluation of treating psychologist Jessica Long’s opinions and in the development of the medical record, including missing records from an intensive partial hospitalization program. The case is remanded for further proceedings, including additional record development and evaluation of Plaintiff’s physical limitations.

Holdings

1. The ALJ did not adequately evaluate Dr. Long's opinions because the ALJ failed to meaningfully address the opinions' detailed narrative support and identified no specific treatment evidence inconsistent with them.
2. The ALJ erred by failing to obtain known treatment and progress records from Plaintiff's intensive partial hospitalization program and then relying on the resulting incomplete record to discount supportive medical opinion evidence.
3. The RFC and step-five findings could not be upheld because further development of the record and proper consideration of the medical evidence were required before those findings could be made.

Questions Presented

1. Whether the ALJ adequately evaluated the supportability and consistency of treating psychologist Jessica Long's medical opinions under 20 C.F.R. § 404.1520c.
2. Whether the ALJ failed to develop the administrative record by not obtaining known treatment and progress records from Plaintiff's partial hospitalization program.
3. Whether the ALJ's residual functional capacity and step-five findings could stand when they were based on an inadequately developed record.
4. Whether the case should be remanded for further proceedings or an immediate award of benefits.

Disposition

reversed_and_remanded