Sarah C. v. Frank Bisignano

Summary

The United States District Court for the Middle District of Pennsylvania reviews the denial of Sarah C.'s application for Social Security Disability Insurance benefits. The court concludes that the Administrative Law Judge failed to explain the omission of a persuasive medical consultant's limitation to one- and two-step tasks from the residual functional capacity assessment. The Commissioner's decision is remanded for further proceedings.

Holdings

1. The ALJ erred by failing to address or explain the omission of the one- or two-step task limitation from the RFC and the vocational-expert hypothetical after finding the state-agency psychological consultant's opinion generally persuasive.
2. The error was not harmless because the only identified occupation consistent with a one- or two-step task limitation had only 6,500 nationally available positions, and the decision did not establish that this constituted a significant number of jobs.
3. The court declined to reach Plaintiff's remaining arguments because remand for reconsideration of the RFC could produce a different result and render those arguments moot.

Questions Presented

1. Whether the ALJ's RFC assessment was supported by substantial evidence when the ALJ found persuasive a medical opinion limiting Plaintiff to one- or two-step tasks but did not include or explain the omission of that limitation.
2. Whether the omission was harmless in light of the vocational expert's identified occupations and the number of nationally available jobs.
3. Whether the court should address Plaintiff's remaining challenges concerning evaluation of her seizures and symptoms.

Disposition

vacated