Alexandra S. v. Frank J. Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Southern District of Illinois reviews the denial of Alexandra S.’s application for Disabled Adult Child benefits under Title II of the Social Security Act. The court concludes that the ALJ improperly assessed the significance of the plaintiff’s Ehlers-Danlos syndrome diagnosis without obtaining updated medical scrutiny or expert opinion addressing its effect on her residual functional capacity. The Commissioner’s decision is reversed and remanded.

Holdings

1. The ALJ committed reversible error by relying on medical evidence developed before Plaintiff's Ehlers-Danlos syndrome diagnosis and by determining the diagnosis's functional significance herself without submitting the new and potentially decisive evidence to medical scrutiny.
2. The court did not decide whether the ALJ independently breached a duty to fully and fairly develop the record; the remand was instead required because the ALJ relied on outdated evidence and played doctor.
3. The court did not decide whether the ALJ improperly evaluated the consistency of Plaintiff's statements with the medical evidence.

Questions Presented

1. Whether the ALJ reversibly erred by determining the functional significance of Plaintiff's later Ehlers-Danlos syndrome diagnosis without medical-expert input or an updated medical assessment.
2. Whether the ALJ failed to fully and fairly develop the evidentiary record.
3. Whether the ALJ improperly evaluated the consistency of Plaintiff's statements with the medical evidence.

Disposition

reversed_and_remanded