Aaron W. v. Commissioner of Social Security

Summary

This Report-Recommendation addresses Aaron W.'s challenge under 42 U.S.C. § 405(g) to the Commissioner of Social Security's denial of Supplemental Security Income benefits. The magistrate judge recommends granting Plaintiff's motion for judgment on the pleadings, denying the Commissioner's motion, and remanding for further administrative proceedings. The recommended remand is based in part on the ALJ's failure to investigate possible reasons for Plaintiff's limited follow-up treatment, including his housing instability, and on deficiencies in evaluating subjective symptoms and medical opinions.

Holdings

1. An ALJ may not rely on a claimant's lack of treatment or failure to follow recommended treatment as evidence undermining subjective symptoms without considering and, where appropriate, inquiring into possible reasons for that lack of treatment. The ALJ erred by failing to investigate whether Plaintiff's homelessness affected his ability to obtain medical care.
2. The ALJ must adequately explain the supportability and consistency of each medical opinion under 20 C.F.R. § 416.920c and must evaluate opinions in relation to the other medical evidence rather than in isolation.

Questions Presented

1. Whether the ALJ erred by relying on Plaintiff's failure to obtain recommended follow-up treatment without inquiring into possible reasons, including the effect of homelessness on his ability to obtain care.
2. Whether the ALJ adequately evaluated the supportability and consistency of the medical opinions under 20 C.F.R. § 416.920c.
3. Whether the ALJ sufficiently explained the consistency between the opinions of the examining physicians and the non-examining consultants when determining Plaintiff's residual functional capacity.

Disposition

reversed_and_remanded