M.J.R. v. Frank Bisignano

Summary

The United States District Court for the Northern District of California reviewed a partially unfavorable Social Security decision concerning M.J.R.'s applications for disability insurance benefits and supplemental security income. The court held that the ALJ inadequately evaluated the supportability and consistency of treating physician Anne Rosenthal's opinions, including the retrospective limitations relevant to the period before February 1, 2017. The court reversed the Commissioner's decision and remanded for further administrative proceedings.

Holdings

1. An ALJ must explicitly address the supportability and consistency factors when evaluating medical opinions, and the analysis must meaningfully engage with the opinion and the relevant evidence.
2. An ALJ may consider a medical source's specialization, but may not reject the source's opinions solely because the source is a primary care physician and not a specialist without addressing the required supportability and consistency factors.

Questions Presented

1. Whether the ALJ properly evaluated Dr. Rosenthal's physical medical opinions under the supportability and consistency requirements of 20 C.F.R. § 404.1520c.
2. Whether the ALJ properly evaluated Dr. Rosenthal's mental functional opinions when the ALJ relied only on her status as a primary care physician rather than addressing supportability and consistency.
3. Whether the Commissioner's decision denying DIB benefits before February 1, 2017 and through M.J.R.'s date last insured was supported by substantial evidence and applied proper legal standards.

Disposition

reversed_and_remanded