Robert Scott Miller v. Frank Bisignano, Commissioner Social Security Administration

Summary

A United States magistrate judge recommends reversing the Commissioner of Social Security’s denial of Robert Scott Miller’s disability insurance benefits claim and remanding under sentence four of 42 U.S.C. § 405(g). The report finds that the ALJ did not adequately address Miller’s vision impairments and did not sufficiently evaluate whether his primary headache disorder medically equaled Listing 11.02B. The recommendation directs further consideration of the evidence and additional vocational-expert limitations as supported by the record.

Holdings

1. The ALJ failed to adequately address evidence of Miller's vision impairment, including diplopia, palinopsia, and a left-eye visual-field defect, when determining his residual functional capacity. Remand was necessary for fuller development and evaluation of the vision-related limitations.
2. The ALJ must reevaluate whether Miller's primary headache disorder medically equals the severity and duration criteria of Listing 11.02B, including consideration of the headache forms completed by Dr. Ann-Marie Magre.

Questions Presented

1. Whether the ALJ adequately evaluated Miller's alleged vision impairment and incorporated supported vision-related limitations into the residual functional capacity assessment.
2. Whether the ALJ adequately evaluated whether Miller's primary headache disorder medically equaled the severity and duration criteria of Listing 11.02B.
3. Whether the Commissioner's decision should be reversed and remanded under sentence four of 42 U.S.C. § 405(g).

Disposition

reversed_and_remanded