Audrey Marie Plummer v. Commissioner of Social Security

Summary

The court granted Audrey Marie Plummer’s motion for judgment on the administrative record and remanded her Social Security disability insurance benefits claim for further administrative proceedings. The court held that the ALJ adequately addressed the consistency of a state-agency medical consultant’s opinion but failed to explain the opinion’s supportability as required by the applicable regulations. This failure prevented meaningful judicial review of the disability determination.

Holdings

1. The ALJ sufficiently explained the consistency factor by identifying later medical evidence and the totality of the record as contradicting or weakening Dr. McLarnon's sedentary-work assessment.
2. The ALJ failed to explain whether and why Dr. McLarnon's opinion was supported by her own findings and explanations, as required by 20 C.F.R. § 404.1520c(b)(2).
3. Remand to the Social Security Administration was required for further administrative proceedings consistent with the memorandum opinion.

Questions Presented

1. Whether the ALJ's evaluation of Dr. McLarnon's prior administrative medical findings complied with the requirement to explain the supportability and consistency factors under 20 C.F.R. § 404.1520c.
2. Whether the ALJ's residual functional capacity determination was supported by substantial evidence.
3. Whether remand was required because the ALJ failed to explain the supportability of Dr. McLarnon's opinion.

Disposition

reversed_and_remanded