Rhonda Martz v. Frank Bisgnano, Commissioner, Social Security Administration

Summary

The court reviews the Commissioner of Social Security’s denial of Rhonda Martz’s claim for disability insurance benefits. It concludes that the administrative law judge failed to adequately consider Martz’s migraine headaches at step two and in the residual functional capacity assessment, including limitations identified in medical opinions. The court reverses the denial of benefits and remands the matter to the Commissioner for further consideration under sentence four of 42 U.S.C. § 405(g).

Holdings

1. The ALJ's decision was not supported by substantial evidence because the ALJ omitted migraines at step two and failed to adequately address their effects, including medical-opinion evidence of environmental limitations, in the RFC assessment.

Questions Presented

1. Whether the ALJ erred by failing to address Martz's migraines at step two and in the RFC assessment.
2. Whether the RFC was supported by substantial evidence when the ALJ did not explain the omission of migraine-related limitations identified in medical opinions.
3. Whether the step-five determination was supported when it relied on an RFC that did not adequately account for Martz's migraines.

Disposition

reversed_and_remanded