Toni S. v. Commissioner of Social Security

Summary

The United States District Court for the Western District of Michigan reviewed an appeal from the denial of Plaintiff’s application for Supplemental Security Income. The court held that the ALJ failed to adequately explain the evidentiary basis for the residual functional capacity limitation allowing a sit/stand option and failed to address Plaintiff’s alleged need to lie down during the day. The court reversed the ALJ’s decision and remanded the matter for further consideration.

Holdings

1. The ALJ's RFC determination was not adequately explained because the ALJ did not identify medical or nonmedical evidence showing that Plaintiff could perform light work with a sit/stand option every hour for five minutes.
2. The ALJ erred by failing to address Plaintiff's complaints that she needed to lie down during the day.

Questions Presented

1. Whether the ALJ's residual functional capacity determination was supported by substantial evidence and adequately explained.
2. Whether the ALJ adequately addressed Plaintiff's testimony that she needed to lie down during the workday.
3. Whether the ALJ applied the correct legal standards in evaluating Plaintiff's pain and symptoms.

Disposition

reversed_and_remanded