Jordan T. R. v. Frank Bisignano, Commissioner of Social Security

Summary

The court reviews a Social Security disability benefits determination under 42 U.S.C. § 405(g). It reverses the administrative law judge’s decision and remands because the ALJ failed to adequately address the plaintiff’s reported fatigue, medication-related tiredness, and need for daily naps when evaluating subjective symptoms and formulating the residual functional capacity. The court does not reach the plaintiff’s remaining arguments.

Holdings

1. The ALJ erred by failing to address Plaintiff's asserted need to lie down or nap daily and by failing to explain why that symptom was not credible or how it affected the residual functional capacity.
2. Remand was warranted because the ALJ failed to build an accurate and logical bridge from the evidence concerning fatigue to the RFC and disability determination.

Questions Presented

1. Whether the ALJ adequately evaluated Plaintiff's subjective symptoms under SSR 16-3p, particularly his alleged fatigue and need to take daily naps.
2. Whether the ALJ adequately explained the residual functional capacity finding in light of Plaintiff's testimony concerning fatigue, medication side effects, and required rest.

Disposition

reversed_and_remanded