Andrew L. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Illinois reviewed the denial of Andrew L.'s applications for disability insurance benefits and supplemental security income. The court held that the administrative law judge failed to adequately explain the assessed social-interaction limitations, reconcile conflicting evidence, and account for accommodations provided in educational and vocational settings. The court remanded the matter for further administrative proceedings.

Holdings

1. The ALJ's assessed social-interaction limitations lacked the support of substantial evidence because the ALJ did not adequately consider or reconcile evidence documenting Andrew's social-communication difficulties and did not explain the basis for limiting him to occasional interactions with supervisors and coworkers.
2. The ALJ erred by failing to explain how Andrew's participation in education, vocational programs, and limited work activities with accommodations and direct support demonstrated that he could sustain full-time competitive employment.
3. The ALJ did not adequately explain why the state agency psychologist's opinion that Andrew should have no public contact and minimal contact with supervisors and coworkers was inconsistent with or unsupported by the record, as required by 20 C.F.R. § 404.1520c.
4. The errors were not harmless because the vocational expert testified that a person with Andrew's RFC had to be able to accept and respond appropriately to criticism from supervisors, an ability directly implicated by the unresolved social-interaction evidence.

Questions Presented

1. Whether the ALJ adequately evaluated and incorporated Andrew's social-interaction limitations into the RFC.
2. Whether the ALJ sufficiently explained how Andrew's accommodated education, vocational training, and work activities supported the ability to sustain full-time competitive employment.
3. Whether the ALJ adequately evaluated conflicting evidence, including the state agency psychologist's opinion that Andrew should have minimal contact with supervisors and coworkers, under 20 C.F.R. § 404.1520c.
4. Whether the ALJ's errors were harmless in light of the vocational expert's testimony.

Disposition

remanded