Dakita P. v. Frank Bisignano, Commissioner of Social Security

Summary

The court grants plaintiff’s motion for summary remand, denies the Commissioner’s motion for summary judgment, and remands the Social Security disability-benefits case for further administrative proceedings. The court concludes that the ALJ failed to explain whether and how the plaintiff’s chronic migraines and related symptoms caused work-related limitations or were incorporated into the residual functional capacity assessment. The court holds that the omission prevents meaningful judicial review and is not harmless.

Holdings

1. The ALJ's decision was not supported by substantial evidence because it did not explain whether plaintiff's migraines caused work-related limitations or whether the RFC incorporated any such limitations.
2. An ALJ must evaluate all limitations arising from medically determinable impairments, including impairments found not severe, and must provide a narrative explanation connecting the evidence to each RFC conclusion.

Questions Presented

1. Whether the ALJ's residual functional capacity assessment was supported by substantial evidence when the ALJ found plaintiff's migraines non-severe but did not explain whether the migraines caused work-related limitations or how the RFC accounted for them.
2. Whether the omission was harmless because the vocational expert identified jobs available under additional restrictions.

Disposition

reversed_and_remanded