Catharine G. v. Frank J. Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of North Carolina reviews the denial of Catharine G.'s claim for Disability Insurance Benefits under the Social Security Act. The court concludes that the Administrative Law Judge inadequately evaluated the claimant's subjective complaints and documented obsessive-compulsive disorder symptoms, including the significance of clinical stability findings and other mental-status-examination results. The court remands the matter for further administrative proceedings.

Holdings

1. The ALJ failed to support with substantial evidence the evaluation discounting Plaintiff's subjective reports concerning the intensity, persistence, and limiting effects of her OCD symptoms.
2. Because the ALJ relied on the same improper rationales to discount the opinions of Dr. Conner and LCSW Milan, the ALJ also erred in evaluating those opinions.

Questions Presented

1. Whether the ALJ adequately evaluated Plaintiff's subjective reports concerning the intensity, persistence, and limiting effects of her OCD symptoms.
2. Whether the ALJ improperly relied on generally stable mental-status examinations, normal findings unrelated to Plaintiff's OCD symptoms, and Plaintiff's self-directed benzodiazepine taper to discount her subjective symptom reports.
3. Whether the ALJ adequately evaluated the persuasiveness of the opinions of treating psychiatrist Dr. Matthew Conner and treating therapist Robert Milan, LCSW.
4. Whether the Commissioner's final decision should be vacated and remanded under sentence four of 42 U.S.C. § 405(g).

Disposition

vacated