Alyssa Nicole Stremme v. Commissioner of Social Security

Summary

The United States District Court for the Northern District of Indiana reviews Alyssa Nicole Stremme’s challenge to the denial of Social Security disability insurance benefits and supplemental security income. The court concludes that the ALJ failed to adequately explain the handling of Plaintiff’s mild mental-functioning limitations, particularly in concentration, persistence, or pace and interaction with others, and failed to account for those limitations in the residual functional capacity assessment. The court remands the case to the Social Security Administration for further proceedings.

Holdings

1. The ALJ failed to provide a sufficient explanation for finding mild limitations in concentration, persistence, or pace because the decision did not explain how evidence that Plaintiff was alert and answered questions during appointments affected her ability to sustain work-related tasks.
2. The ALJ did not adequately explain why Plaintiff's mild limitation in interacting with others required no corresponding RFC restriction.
3. The error was not harmless because the court could not predict with great confidence what the result of remand would be.

Questions Presented

1. Whether the ALJ adequately explained the finding that Plaintiff had mild limitations in concentration, persistence, or pace and incorporated those limitations into the RFC.
2. Whether the ALJ adequately explained the finding that Plaintiff had a mild limitation in interacting with others and incorporated that limitation into the RFC.
3. Whether the ALJ's failure to explain the treatment of the mental-functioning limitations was harmless error.

Disposition

reversed_and_remanded