Michael Sean Cronican v. Commissioner of Social Security

Summary

This Report and Recommendation addresses Michael Sean Cronican’s appeal from the denial of his application for Social Security Disability Insurance benefits. The magistrate judge recommends reversing the Commissioner’s decision and remanding for further proceedings because the ALJ did not adequately consider or explain whether Cronican required a bariatric chair and the effect of that limitation on available work. The recommendation does not reach Cronican’s second assignment of error concerning the evaluation of his symptom allegations.

Holdings

1. The ALJ erred by failing to explain whether Cronican's approximately 500-pound weight required a bariatric chair and, if so, what effect that limitation would have on the jobs available to him. The matter should be reversed and remanded for further consideration.
2. The court did not reach the second assignment of error because the first assignment independently required remand.

Questions Presented

1. Whether the ALJ's residual functional capacity assessment was supported by substantial evidence when it failed to address whether Cronican's weight required use of a bariatric chair.
2. Whether the ALJ properly evaluated Cronican's symptom allegations under the applicable regulations and case law.

Disposition

reversed_and_remanded