Shawn S. v. Commissioner of Social Security

Summary

This Report and Recommendation concerns the fourth federal action arising from Shawn S.'s application for Supplemental Security Income. The magistrate judge recommends reversing the Commissioner's unfavorable decision, awarding benefits for a closed period from September 26, 2013, through December 31, 2014, and remanding for further proceedings concerning the period beginning January 1, 2015. The recommendation addresses the evaluation of psychological evidence, residual functional capacity, and the substantial-evidence standard under 42 U.S.C. § 405(g).

Holdings

1. The ALJ reversibly erred by failing to explain how Dr. Lace's recommended limitations incorporated or rendered unnecessary the additional limitations identified by Drs. Sisson, Roach, Finnerty, and Zeune, including repeated instructions, increased supervision, minimal distractions, gradual implementation of changes, and flexible breaks.
2. The ALJ reversibly erred by relying heavily on later evidence and failing to adequately consider significant evidence from the period following the September 26, 2013 SSI application through December 31, 2014.
3. The record overwhelmingly established disability during the closed period, warranting an immediate award of benefits for that period.
4. An immediate award was not warranted for the period beginning January 1, 2015; the matter should be remanded for further proceedings concerning that period.

Questions Presented

1. Whether the ALJ failed to build a logical bridge between the RFC, Dr. Lace's testimony, and the decision to discount additional limitations identified by other psychologists.
2. Whether the ALJ improperly failed to consider evidence from the entire relevant period, particularly evidence from September 26, 2013 through December 31, 2014.
3. Whether the record established entitlement to an immediate award of SSI benefits for a closed period and required further proceedings for the later period.

Disposition

reversed_and_remanded