Samantha B. v. Commissioner of Social Security

Summary

The Report and Recommendation addresses Samantha B.’s action seeking review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s denial of Disability Insurance Benefits. It recommends reversing the nondisability finding and remanding under sentence four because the Administrative Law Judge did not adequately explain the rejection of state-agency psychologists’ opinions concerning flexibility in scheduling work breaks.

Holdings

1. The ALJ did not adequately explain the rejection of the state agency psychologists' opinion that Plaintiff required some flexibility in scheduling breaks because the explanation was circular and did not address how the psychologists' evidence and reasoning supported or failed to support that limitation.
2. The ALJ's inadequate supportability analysis was not harmless because proper consideration of the flexible-break limitation could have resulted in a residual functional capacity containing work-preclusive limitations.

Questions Presented

1. Whether the ALJ adequately evaluated the supportability of the state agency psychological consultants' opinions regarding the need for flexibility in scheduling work breaks.
2. Whether the ALJ's failure to articulate a logical bridge between the evidence and rejection of the flexible-break limitation was harmless.
3. Whether the court needed to decide the separate challenge to the ALJ's consistency evaluation.

Disposition

reversed_and_remanded