Carla D. v. Commissioner of Social Security

Summary

The United States District Court for the Southern District of Ohio reviewed the Commissioner of Social Security’s denial of Carla D.’s application for supplemental security income. The court held that the administrative law judge inadequately evaluated the functional effects of the claimant’s obesity under Social Security Ruling 19-2p and failed to provide substantial support for the residual functional capacity determination. The court reversed the non-disability determination and remanded the matter under Sentence Four of 42 U.S.C. § 405(g).

Holdings

1. The ALJ's evaluation of Plaintiff's obesity was inadequate because the explanation did not logically connect the record evidence to the RFC limitations and was not supported by substantial evidence.
2. The Commissioner's non-disability determination must be reversed and the matter remanded to the Commissioner and the ALJ for further consideration.

Questions Presented

1. Whether the ALJ adequately evaluated the limiting effects of Plaintiff's obesity when determining her residual functional capacity.
2. Whether the Commissioner's denial of SSI was supported by substantial evidence and complied with applicable Social Security regulations and rulings.

Disposition

reversed_and_remanded