Alexis Jose Troche v. Frank Bisignano, Commissioner of the Social Security Administration

Summary

The United States District Court for the Middle District of Florida remanded the Commissioner of Social Security’s decision denying Alexis Jose Troche’s claim for disability insurance benefits. The court held that the administrative law judge did not adequately explain the supportability and consistency of several medical opinions and prior administrative findings under 20 C.F.R. § 404.1520c. The court declined to reach Troche’s remaining arguments concerning the residual functional capacity determination.

Holdings

1. The ALJ failed to adequately explain the consistency and supportability of Dr. Patel's opinion as required by 20 C.F.R. § 404.1520c, and the resulting decision was not supported by substantial evidence.
2. The ALJ adequately addressed consistency but failed to address supportability for the opinions of Dr. Walker and Dr. Morgan-Smith, contrary to 20 C.F.R. § 404.1520c.
3. The ALJ failed to adequately explain the consistency of Dr. Goldstein's opinion with the other evidence in the record, as required by 20 C.F.R. § 404.1520c.
4. The court declined to address the remaining RFC arguments because the deficiencies in the ALJ's evaluation of the medical opinions independently required remand.

Questions Presented

1. Whether the ALJ properly evaluated the persuasiveness of the medical opinions and prior administrative medical findings under 20 C.F.R. § 404.1520c.
2. Whether the ALJ's residual-functional-capacity determination accounted for all of Troche's impairments.

Disposition

remanded