Adrienne Lombardo v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of Pennsylvania remands Adrienne Lombardo’s Social Security disability case for further proceedings. The court holds that the Administrative Law Judge failed to explain why a one- to two-step task limitation stated by a persuasive state-agency medical consultant was omitted from the residual functional capacity assessment. Because the vocational testimony identified jobs requiring reasoning levels exceeding that limitation, the court found the decision insufficiently explained for meaningful judicial review.

Holdings

1. When an ALJ finds persuasive a medical opinion containing a limitation to one- and two-step tasks, the ALJ must either include that limitation in the RFC and restrict the claimant to reasoning-level-one occupations, or identify substantial evidence supporting rejection of the limitation.
2. A limitation to one- and two-step tasks is equivalent to a limitation to reasoning-level-one occupations; occupations requiring reasoning level two or three are not compatible with that limitation absent substantial evidence explaining otherwise.
3. The court could not treat the ALJ's omission as harmless or supply a different rationale for the ALJ's decision where the ALJ had found the relevant opinion persuasive but did not address a material limitation.

Questions Presented

1. Whether the ALJ erred by finding a state-agency medical opinion persuasive while failing to incorporate that opinion's limitation to one- and two-step tasks into the RFC or explain why the limitation was rejected.
2. Whether the omission was harmless when the ALJ relied on occupations requiring reasoning levels two or three despite the one- and two-step task limitation.
3. Whether the ALJ's decision adequately articulated the reasoning connecting the medical evidence, RFC, and denial of benefits to permit substantial-evidence review.

Disposition

vacated