Laronda T. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Illinois reviewed the Commissioner of Social Security’s denial of Laronda T.’s claims for Disability Insurance Benefits and Supplemental Security Income. The court granted Plaintiff’s motion to reverse in part and denied the Commissioner’s cross-motion for summary judgment, finding errors in the step-five vocational analysis, consideration of medical-opinion evidence concerning the need for a companion, and assessment of daily activities and subjective symptoms. The matter was remanded to the Commissioner for further proceedings.

Holdings

1. The ALJ's step-five finding was inadequately supported because the ALJ mistakenly characterized the identified jobs as unskilled when they were semi-skilled and did not explain how Plaintiff could transition from her prior unskilled custodial work to those jobs.
2. The ALJ erred by failing to address the medical expert's opinion that Plaintiff should not be left alone, despite finding the expert's opinions markedly persuasive and despite vocational-expert testimony that a person requiring a companion throughout the workday would have no competitive work.
3. The ALJ's symptom assessment was inadequate because it did not explain how Plaintiff's ability to perform limited household activities, such as wiping counters, was inconsistent with her alleged disabling symptoms or with the medical evidence.

Questions Presented

1. Whether the ALJ properly established at step five that significant numbers of jobs existed that Plaintiff could perform.
2. Whether the ALJ adequately considered the medical expert's opinion that Plaintiff should not be left alone.
3. Whether the ALJ adequately evaluated Plaintiff's subjective symptoms and daily activities.

Disposition

reversed_and_remanded