Lauren R. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Southern District of California reviewed the denial of Lauren R.'s applications for Social Security disability insurance benefits and supplemental security income. The court vacated the Commissioner's decision and remanded for further administrative proceedings because the ALJ did not sufficiently explain the treatment of Plaintiff's subjective testimony and potentially also needed to reassess a nurse practitioner's medical opinion.

Holdings

1. The ALJ's decision did not identify with sufficient detail what portions of Plaintiff's testimony were credited and what portions were undermined by the evidence, and its explanation of the alleged inconsistency with the medical record was too unclear to permit effective judicial review.
2. The court did not decide whether the ALJ's evaluation of Baker's opinion independently required remand, but directed that the ALJ may re-address the opinion on remand.

Questions Presented

1. Whether the ALJ provided sufficiently specific, clear, and convincing reasons for discounting Plaintiff's subjective symptom testimony.
2. Whether the ALJ adequately explained the finding that nurse practitioner Shannon Baker's medical questionnaire was inconsistent with the medical and other evidence.
3. Whether the Commissioner's denial of benefits should be affirmed, modified, reversed, or remanded under 42 U.S.C. § 405(g).

Disposition

reversed_and_remanded