Autumn D. S. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Indiana reviewed the denial of Autumn D. S.’s application for Disability Insurance Benefits. The court held that the administrative law judge improperly characterized and relied on the claimant’s hobbies and daily activities when evaluating medical opinions and the Paragraph B criteria. The court reversed and remanded the Commissioner’s decision for further administrative proceedings.

Holdings

1. The ALJ did not adequately evaluate the medical opinions because the ALJ relied on a mischaracterized account of plaintiff's hobbies and failed to address plaintiff's reported limitations in performing those activities.
2. The RFC assessment was not supported by substantial evidence because the ALJ again relied on a misconstrued account of plaintiff's hobbies without acknowledging plaintiff's reported difficulties and limitations in performing them.

Questions Presented

1. Whether the ALJ properly evaluated the persuasiveness of the medical opinions by considering plaintiff's daily activities.
2. Whether the ALJ's RFC assessment and evaluation of plaintiff's symptoms were supported by substantial evidence when the ALJ relied on a mischaracterized account of plaintiff's hobbies.

Disposition

reversed_and_remanded