Paige C. v. Commissioner of Social Security

Summary

This Report and Recommendation addresses Paige C.’s challenge to the Commissioner of Social Security’s denial of Child’s Insurance Benefits and Supplemental Security Income. The magistrate judge concludes that the ALJ failed to build an accurate and logical bridge between the evidence concerning Plaintiff’s physical impairments and the residual functional capacity assessment. The recommendation is that the Commissioner’s decision be reversed and the matter remanded for further proceedings.

Holdings

1. The ALJ's RFC determination was unsupported by substantial evidence because the ALJ did not adequately explain how the RFC accommodated Plaintiff's severe physical impairments and related nonexertional limitations.
2. The ALJ reversibly erred in evaluating Plaintiff's symptom severity by relying heavily on normal imaging, failing to consider significant evidence supporting Plaintiff's complaints, mischaracterizing her treatment as conservative management, and failing to adequately explain the treatment of complaints concerning fibromyalgia, POTS, gastroparesis, and endometriosis.
3. The ALJ's Step Five finding was unsupported by substantial evidence because the RFC did not accurately portray Plaintiff's impairments and limitations, and the vocational expert's testimony based on that RFC therefore could not support the finding.
4. Plaintiff's challenge to the characterization of the identified sedentary jobs as semi-skilled rather than unskilled was not well-taken, and in any event was harmless because the vocational expert also identified three unskilled light jobs consistent with the RFC.

Questions Presented

1. Whether the ALJ built an accurate and logical bridge between the medical evidence and the RFC.
2. Whether the ALJ properly evaluated Plaintiff's subjective symptoms under 20 C.F.R. § 404.1529 and SSR 16-3p.
3. Whether the ALJ's Step Five finding was supported by substantial evidence, including whether the vocational expert's testimony responded to a hypothetical that accurately portrayed Plaintiff's limitations.
4. Whether the sedentary jobs identified by the vocational expert were inconsistent with the RFC because they were semi-skilled rather than unskilled.

Disposition

reversed_and_remanded