Joshua D. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Iowa reviews an objection to a magistrate judge’s recommendation to affirm the denial of the plaintiff’s application for Social Security disability insurance benefits. The court concludes that the administrative law judge inadequately addressed the potential loss of access to Nurtec and its effect on the plaintiff’s migraines, including the residual functional capacity analysis. The court sustains the objection in part and remands for further development of the record concerning the plaintiff’s access to Nurtec through the relevant period and whether that access would affect the disability determination.

Holdings

1. The ALJ erred by relying on Nurtec's beneficial effects to find the claimant's migraines non-severe and minimally limiting without developing the record regarding whether the claimant had an adequate supply of Nurtec through August 30, 2024, the date of the ALJ's decision.
2. The ALJ erred by failing to address the claimant's service dog as a potential indicator of the severity of his mental impairments and limitations in interacting with others.
3. Substantial evidence supported the ALJ's findings regarding the claimant's forgetfulness, concentration, and ability to manage himself, as well as the decision not to adopt Bethany Williams's more restrictive mental medical source statement.

Questions Presented

1. Whether the ALJ's treatment of the claimant's migraines as non-severe and minimal in the RFC analysis was supported by substantial evidence when continued access to Nurtec was uncertain through the date of the ALJ's decision.
2. Whether the ALJ adequately considered the claimant's service dog as evidence relevant to the severity of his mental impairments and ability to interact with others.
3. Whether substantial evidence supported the ALJ's evaluation of the claimant's other mental functional areas and rejection of the treating psychiatric provider's opinion.

Disposition

reversed_and_remanded