Megan H. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Illinois reviewed the denial of Megan H.'s Social Security disability insurance benefits claim. The court held that the Administrative Law Judge inadequately evaluated Megan's subjective symptoms, medical opinion evidence, and residual functional capacity. The court granted the remand request and remanded the matter for further proceedings.

Holdings

1. The ALJ improperly evaluated Megan's subjective symptoms by selectively citing a limited number of mental-status examinations, failing to confront abnormal findings and other contrary evidence, and relying on incompletely described daily activities without adequately connecting them to the ability to sustain full-time work.
2. The ALJ failed to properly evaluate the medical opinions because she did not adequately address the required supportability and consistency factors and did not fairly consider evidence supporting the opinions she rejected.
3. The RFC assessment was not supported by an adequate explanation because the ALJ failed to account for evidence indicating that Megan could not reliably leave home for work, had significant concentration problems, and could not perform even basic work tasks.

Questions Presented

1. Whether the ALJ improperly evaluated Megan's subjective symptoms by selectively citing normal or unremarkable mental-status examinations, relying on incompletely described daily activities, and failing to address contrary evidence.
2. Whether the ALJ properly evaluated the supportability and consistency of the medical opinions concerning Megan's mental impairments.
3. Whether the ALJ's residual functional capacity assessment adequately incorporated all of Megan's supported mental limitations and provided a logical bridge from the evidence to the RFC.

Disposition

remanded