Rodney H. v. Frank Bisignano

Summary

The United States District Court for the Southern District of Texas reviews the denial of Rodney H.’s application for supplemental security income. The court grants Plaintiff’s motion for summary judgment, denies the Commissioner’s motion, and reverses and remands because the ALJ’s residual functional capacity determination was not supported by substantial evidence and relied on an unsupported interpretation of the medical record. The court does not reach the plaintiff’s remaining arguments concerning vocational-expert testimony, assistive-device use, and Listing 1.18.

Holdings

1. The ALJ's RFC determination was not supported by substantial evidence because the ALJ inferred Plaintiff's exertional and functional capacities from medical records without a medical opinion or other evidence establishing how Plaintiff's impairments affected his ability to sustain work-related functions.
2. The RFC error was harmful because further development of the record could produce evidence that would lead to a different disability determination.

Questions Presented

1. Whether the ALJ's residual functional capacity determination was supported by substantial evidence when the ALJ rejected or lacked medical opinions addressing Plaintiff's work-related functional limitations.
2. Whether the ALJ's failure to develop evidence concerning Plaintiff's functional capacity was harmful.
3. Whether the ALJ properly resolved conflicts between the vocational expert's testimony and the Dictionary of Occupational Titles, incorporated Plaintiff's assistive-device use into the RFC, and evaluated Listing 1.18.

Disposition

reversed_and_remanded