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

Summary

The United States District Court for the Middle District of North Carolina reviewed the denial of Breon M.'s applications for Disability Insurance Benefits and Supplemental Security Income. The court held that the Administrative Law Judge failed to adequately analyze and explain the plaintiff's ability to sit, particularly in light of conflicting medical and vocational evidence. The court reversed the Commissioner's decision and remanded the matter under sentence four of 42 U.S.C. § 405(g).

Holdings

1. When a claimant's ability to sit is materially contested by contradictory evidence, the ALJ must separately analyze that function and explain, through a narrative discussion, how the evidence supports the resulting sitting limitation or lack thereof. The ALJ failed to do so here.
2. The ALJ's general references to the non-static nature of Plaintiff's symptoms and inconsistency with objective findings did not adequately explain the rejection of the sitting limitations reflected in the record.
3. The RFC error was harmful because the vocational experts testified that a sit/stand option or required position changes would eliminate the identified jobs and prevent full-time competitive employment.

Questions Presented

1. Whether the ALJ adequately assessed Plaintiff's ability to sit on a sustained basis when formulating the residual functional capacity.
2. Whether the ALJ adequately explained the rejection of evidence and medical opinions supporting sitting limitations.
3. Whether the ALJ's failure to address contested sitting limitations was harmless when vocational-expert testimony indicated that a sit/stand option would render Plaintiff unemployable.

Disposition

reversed_and_remanded