Harriet G. v. Frank Bisignano, Acting Commissioner of Social Security

Summary

The United States District Court for the Northern District of Illinois reviewed the denial of Harriet G.’s application for Social Security disability insurance benefits. The court held that the ALJ failed to explain how the plaintiff’s mild limitation in concentration, persistence, or pace affected the residual functional capacity assessment, particularly because the ALJ found that she could perform skilled past relevant work. The court reversed the Commissioner’s decision and remanded for further proceedings.

Holdings

1. The ALJ committed reversible error by finding that Plaintiff had a mild limitation in concentration, persistence, or pace but failing either to include corresponding mental restrictions in the RFC or explain why the limitation caused no functional restrictions.
2. The court declined to reach the remaining arguments because the ALJ's failure to evaluate the mild concentration, persistence, or pace limitation independently required remand.

Questions Presented

1. Whether the ALJ erred by finding a mild limitation in concentration, persistence, or pace at step two but failing either to incorporate that limitation into the RFC or explain why it required no functional restriction.
2. Whether the ALJ adequately evaluated Plaintiff's sitting limitations and subjective symptom statements and the third-party function report.

Disposition

reversed_and_remanded