Mary B. S. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Northern District of Oklahoma reviewed the Commissioner of Social Security’s denial of Mary B. S.’s disability benefits claims under Titles II and XVI of the Social Security Act. The court held that the ALJ’s physical residual functional capacity determination was unsupported by substantial evidence because it failed to address objective evidence of continuing upper-extremity pain and functional limitations. The court reversed and remanded the decision for further proceedings.

Holdings

1. The ALJ's physical RFC assessment was not supported by substantial evidence because the ALJ selectively discussed the evidence and failed to address or reconcile objective medical records showing continuing limitations in the plaintiff's arms and left shoulder.

Questions Presented

1. Whether the ALJ's physical residual functional capacity assessment was supported by substantial evidence where the ALJ failed to address probative medical evidence of continuing upper-extremity pain and functional limitations.
2. Whether the ALJ properly evaluated the plaintiff's mental limitations and the medical evidence supporting them.
3. Whether the ALJ properly evaluated the plaintiff's subjective complaints of pain.

Disposition

reversed_and_remanded