Annette Straub v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Middle District of Pennsylvania reviews the Commissioner of Social Security’s denial of Annette Straub’s claims for disability insurance benefits and supplemental security income. The court concludes that the administrative decision is unsupported by substantial evidence in material respects, including the evaluation of Straub’s migraine headaches, and remands the case to the Commissioner for further proceedings.

Holdings

1. The ALJ failed to adequately articulate the step-three analysis because the decision did not address the requirements of Listing 11.02B or 11.02D or the factors identified in Social Security Ruling 19-4p, including headache frequency, severity and duration, treatment side effects, and functional limitations.
2. The error was not harmless because Straub identified record evidence that could support application of Listing 11.02, and the court could not conclude that no set of facts would entitle her to benefits.
3. Remand for further proceedings was appropriate rather than an immediate award of benefits.

Questions Presented

1. Whether the ALJ adequately articulated the step-three analysis concerning whether Straub's migraine headaches medically equaled Listing 11.02.
2. Whether the ALJ's failure to adequately analyze medical equivalence was harmless.
3. Whether remand for further administrative proceedings or an award of benefits was the appropriate remedy.

Disposition

vacated