E. Michael E. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Illinois granted E. Michael E.’s motion to reverse and remand the denial of Social Security disability benefits and denied the Commissioner’s motion for summary judgment. The court held that the administrative law judge inadequately explained the rejection of state-agency medical opinions and created an evidentiary gap in determining the plaintiff’s residual functional capacity for medium work. The case was remanded for further administrative proceedings under sentence four of 42 U.S.C. § 405(g).

Holdings

1. The ALJ failed to sufficiently explain the supportability of the three state-agency medical consultants' opinions because she conclusorily stated that the opinions were not supported by objective medical evidence without identifying the objective evidence or explaining why it failed to support the opinions.
2. The RFC finding was not supported by substantial evidence because, after rejecting all relevant medical opinions addressing plaintiff's physical limitations, the ALJ did not identify sufficient evidence tying the record to the medium-work RFC.

Questions Presented

1. Whether the ALJ adequately evaluated the supportability and consistency of the state-agency medical consultants' opinions under the Social Security regulations.
2. Whether the ALJ's RFC finding that plaintiff could perform medium exertional work was supported by substantial evidence after the ALJ rejected all relevant medical opinions concerning plaintiff's physical limitations.
3. Whether the ALJ's failure to sufficiently connect the record evidence to the RFC required remand.

Disposition

reversed_and_remanded