Roy K. 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 Roy K.’s claims for Disability Insurance Benefits and Supplemental Security Income. The court held that the Administrative Law Judge failed to address a medical expert’s opinion concerning Plaintiff’s limitations in handling small objects due to visual impairments. The court granted Plaintiff’s motion in part, denied the Commissioner’s cross-motion for summary judgment, and remanded for further proceedings.

Holdings

1. The ALJ erred by failing to account for the medical expert's opinion that Plaintiff was limited in handling small objects because of his visual impairments and by failing to explain the omission from the residual functional capacity assessment.
2. The Commissioner may not defend the ALJ's decision with a post hoc rationalization that does not appear in the ALJ's decision.

Questions Presented

1. Whether the ALJ's residual-functional-capacity assessment was supported by substantial evidence when it omitted the medical expert's opinion regarding Plaintiff's limitation in handling small objects.
2. Whether the Commissioner could defend the ALJ's decision through a post hoc explanation that the visual-acuity limitation accommodated Plaintiff's ability to work with small objects.

Disposition

remanded