Bobbie R. v. O'Malley

Summary

The court remanded a Social Security disability case for further proceedings. It held that the ALJ failed to adequately consider the plaintiff’s PTSD at Step Two, Step Three, and in formulating the residual functional capacity, and failed to fully develop the record. The court declined to reach the plaintiff’s remaining arguments.

Holdings

1. The ALJ committed legal error by treating or effectively treating Plaintiff's PTSD as subject to exclusion at Step Two without properly applying the de minimis standard, despite substantial record evidence supporting the impairment.
2. The ALJ erred by failing to properly evaluate Plaintiff's PTSD symptoms and limitations under Listing 12.15 and by failing to account for the PTSD evidence when formulating the residual functional capacity.
3. The ALJ failed to fulfill the duty to develop the record fully and fairly regarding Plaintiff's PTSD and its limitations during the relevant disability period.

Questions Presented

1. Whether the ALJ committed legal error by failing to properly evaluate Plaintiff's PTSD at Step Two of the sequential disability analysis.
2. Whether the ALJ adequately considered Plaintiff's PTSD at Step Three under Listing 12.15 and when formulating the residual functional capacity.
3. Whether the ALJ's failure to evaluate the PTSD evidence rendered the Step Three determination and residual functional capacity unsupported by substantial evidence.
4. Whether the case should be remanded for further proceedings rather than having the court reach Plaintiff's remaining arguments.

Disposition

remanded