Carter v. Colvin

Summary

The United States District Court for the Northern District of California granted the plaintiff's motion to remand a Social Security disability case for further proceedings before the Administrative Law Judge. The court found that the ALJ inadequately explained the rejection of a medical opinion concerning the plaintiff's ability to walk and stand, and failed to provide clear and convincing reasons for discounting the plaintiff's testimony about pain and symptoms. The court declined to remand for an immediate award of benefits and directed the Clerk to close the case.

Holdings

1. The ALJ's residual functional capacity determination was defective because the ALJ failed to explain why Dr. Reinking's references to the plaintiff's right-foot impairment and bilateral knee osteoarthritis did not support the limitation to walking or standing for no more than two hours in a workday.
2. The ALJ failed to provide clear and convincing reasons for discounting the plaintiff's testimony about the severity of pain and symptoms.
3. The case was properly remanded for further proceedings before the ALJ rather than for an immediate award of benefits.

Questions Presented

1. Whether the ALJ adequately explained the rejection of Dr. Reinking's limitation that the plaintiff could walk or stand for no more than two hours in a workday.
2. Whether the ALJ provided clear and convincing reasons for discounting the plaintiff's testimony about the severity of pain and symptoms.
3. Whether the case should be remanded for an immediate award of benefits or for further administrative proceedings.

Disposition

remanded