Benjamin Lucas v. Frank Bisignano, Commissioner of Social Security

Summary

This Report and Recommendation addresses Benjamin Michael Lucas’s action seeking judicial review of the Commissioner of Social Security’s denial of Supplemental Security Income benefits. The magistrate judge recommends vacating and remanding the Commissioner’s decision because the ALJ failed to properly evaluate the supportability of psychologist Karin Worrell’s opinions and the state agency psychological consultants’ opinions under the applicable regulations.

Holdings

1. The ALJ adequately addressed the consistency of Dr. Worrell's opinions with the record but failed to properly assess their supportability because he inaccurately characterized Dr. Worrell's detailed explanations as merely a listing of diagnoses and subjective allegations.
2. The ALJ properly evaluated the state-agency psychological consultants' opinions and did not err by considering some mental limitations from the prior ALJ decision.

Questions Presented

1. Whether the ALJ properly evaluated the supportability and consistency of Dr. Worrell's medical opinions under 20 C.F.R. § 416.920c.
2. Whether the ALJ properly evaluated the opinions of the state-agency psychological consultants, including the consultants' reliance on limitations from a prior ALJ decision under Drummond and Earley.

Disposition

remanded