Renee C. Kent v. Frank J. Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Wisconsin reviewed the Commissioner of Social Security’s denial of Renee C. Kent’s applications for disability benefits. The court held that the administrative law judge failed to adequately consider evidence concerning Kent’s left shoulder impairment and related functional limitations. The court reversed the Commissioner’s decision and remanded the matter for further proceedings under sentence four of 42 U.S.C. § 405(g).

Holdings

1. The ALJ erred by failing to address all relevant evidence concerning Plaintiff's left shoulder pain, impairment, and limitations and by failing to explain whether that evidence supported additional residual functional capacity restrictions.
2. Remand was warranted because the ALJ's failure to consider and explain the left-shoulder evidence prevented meaningful judicial review of the RFC and disability determination.

Questions Presented

1. Whether the ALJ adequately considered evidence of Plaintiff's left shoulder impairment, pain, and functional limitations in determining her residual functional capacity.
2. Whether the ALJ's residual functional capacity finding was supported by substantial evidence and adequately explained through an accurate and logical bridge from the evidence to the conclusion.

Disposition

reversed_and_remanded