Joseph A. v. Frank Bisignano, Commissioner of the Social Security Administration

Summary

The United States District Court for the Northern District of Illinois reviewed the denial of Joseph A.'s application for Social Security Disability Insurance benefits. The court granted the plaintiff's motion to reverse, denied the Commissioner's motion for summary judgment, and remanded because the ALJ failed to address checkbox findings concerning the plaintiff's ability to work with coworkers and peers in assessing his mental residual functional capacity.

Holdings

1. The ALJ committed reversible error by failing to address the consultants' checkbox opinions that Plaintiff was moderately limited in working with others and getting along with coworkers or peers.
2. The Commissioner's decision was reversed and the case was remanded for further proceedings because the ALJ's failure to address the material checkbox limitations was reversible error.

Questions Presented

1. Whether the ALJ adequately accounted for the state agency psychological consultants' checkbox findings that Plaintiff was moderately limited in working in coordination with or in proximity to others and getting along with coworkers or peers.
2. Whether the ALJ was required to explain the treatment or exclusion of those checkbox limitations in the residual functional capacity assessment.

Disposition

reversed_and_remanded