Benjamin J. Royer v. Frank J. Bisignano, Commissioner of the Social Security Administration

Summary

The United States District Court for the Eastern District of Wisconsin reviews the denial of Benjamin Royer's application for Social Security disability insurance benefits. The court concludes that the ALJ inadequately evaluated Royer's subjective symptoms by misstating or overemphasizing medication noncompliance and by failing to address the effect of fatigue on his ability to sustain work before his date last insured. The court reverses the unfavorable portion of the decision and remands for further proceedings.

Holdings

1. The ALJ erred by discounting Royer's alleged heart-related symptoms based on treatment noncompliance because the ALJ misstated the record, failed to address evidence that Royer reported compliance during the relevant period, and assumed without supporting evidence or medical opinion that the July 2016 low ejection fraction resulted from noncompliance.
2. The ALJ erred by failing to consider how Royer's alleged fatigue affected his ability to perform sustained work before his date last insured.
3. Because the ALJ's subjective-symptom evaluation lacked logical support and explanation, substantial evidence did not support the RFC or the resulting step-four and step-five findings denying Royer's DIB claim.

Questions Presented

1. Whether the ALJ adequately supported and explained the evaluation of Royer's subjective heart-related symptoms before his date last insured.
2. Whether the ALJ improperly discounted Royer's symptoms based on alleged medication and treatment noncompliance by misstating or ignoring contrary evidence.
3. Whether the ALJ failed to consider Royer's alleged fatigue and its effect on his ability to sustain work activity in the residual-functional-capacity assessment.
4. Whether the ALJ's errors undermined the step-four and step-five findings denying disability insurance benefits.

Disposition

reversed_and_remanded