David L.J. v. Frank Bisignano

Summary

The court reviewed the Commissioner of Social Security’s denial of the plaintiff’s applications for Disability Insurance Benefits and Supplemental Security Income. It granted the plaintiff’s motion for summary judgment, denied the Commissioner’s motion, reversed the decision, and remanded for further proceedings because the ALJ inadequately explained the consistency analysis of a consultative psychologist’s opinion under 20 C.F.R. § 404.1520c.

Holdings

1. The ALJ committed reversible error by rejecting Dr. Stone's opinion based on a conclusory statement that it was inconsistent with the record, without identifying or analyzing the other medical and nonmedical evidence relevant to consistency.
2. A brief mini mental status examination performed by a nonspecialist during an examination focused on physical capabilities was not, without a fulsome explanation, a sufficient basis to disregard the comprehensive opinion of a mental-health specialist.

Questions Presented

1. Whether the ALJ adequately evaluated the supportability and consistency of Dr. Michael Stone's medical opinion under 20 C.F.R. § 404.1520c.
2. Whether the ALJ's conclusory finding that Dr. Stone's opinion was inconsistent with the record constituted reversible error.
3. Whether the case should be remanded for further administrative proceedings.

Disposition

reversed_and_remanded