Nathaniel Aaron Finkin v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of Pennsylvania remanded Nathaniel Aaron Finkin’s Social Security disability case for further consideration. The court held that the ALJ failed to adequately explain why the claimant’s repeated reports and medical-record evidence of severe fatigue were not credited or incorporated into the residual functional capacity assessment. The court did not reach the claimant’s separate challenge to the evaluation of a consultative examiner’s opinion.

Holdings

1. The ALJ failed to satisfy the duty of articulation because the decision did not specifically explain why the claimant's consistent statements about work-preclusive fatigue were not credited despite medical records and third-party evidence corroborating those statements.
2. The RFC was not adequately supported because it included no accommodation for fatigue-related off-task time or absenteeism and the ALJ did not explain that omission.

Questions Presented

1. Whether the ALJ adequately evaluated and articulated the reasons for rejecting or failing to accommodate the claimant's subjective complaints of work-preclusive fatigue.
2. Whether the ALJ's RFC determination was supported by substantial evidence when it included no limitations for off-task time, rest, or absenteeism related to fatigue.
3. Whether the ALJ's failure to explain the omission of fatigue-related limitations required remand.

Disposition

reversed_and_remanded