Manuel McNeely Jr. v. Frank J. Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Southern District of California vacated the Commissioner of Social Security’s denial of disability benefits and remanded for further consideration. The court held that the ALJ failed to adequately account for the plaintiff’s significant glaucoma-related vision impairments, develop the medical record, and include all supported limitations in the vocational expert hypothetical. On remand, the Commissioner was directed to obtain a medical specialist’s opinion regarding work-related limitations resulting from the plaintiff’s primary open-angle glaucoma.

Holdings

1. Where objective medical evidence establishes an underlying impairment, there is no evidence of malingering, and the impairment could reasonably produce the alleged symptoms, an ALJ may reject the claimant's symptom testimony only by providing specific, clear, and convincing reasons. The ALJ's reasons for rejecting McNeely's testimony about recurring vision loss were not convincing.
2. The ALJ erred by failing to further develop the record concerning the work-related functional limitations caused by Plaintiff's glaucoma and visual-field loss.
3. A vocational expert's testimony cannot constitute substantial evidence supporting a step-five finding when the hypothetical does not include all of the claimant's medically supported limitations. The ALJ therefore erred by omitting Plaintiff's visual limitations from the hypothetical.

Questions Presented

1. Whether the ALJ properly evaluated Plaintiff's testimony concerning episodic blindness and visual impairment.
2. Whether the ALJ adequately developed the administrative record regarding the functional effects of Plaintiff's glaucoma.
3. Whether the ALJ's residual-functional-capacity and step-five vocational-expert analysis was supported by substantial evidence when the hypothetical omitted Plaintiff's visual limitations.

Disposition

reversed_and_remanded