Jennifer Ann Sisler v. Commissioner, Social Security Administration

Summary

The United States District Court for the Western District of Missouri reviewed Jennifer Ann Sisler’s challenge under 42 U.S.C. § 405(g) to the denial of supplemental security income benefits. The court held that the ALJ failed to adequately account for or explain the omission of a persuasive limitation concerning Plaintiff’s ability to adapt to workplace changes under Social Security Ruling 96-8p. The court reversed the ALJ’s decision and remanded for a supplemental administrative hearing and a new written decision.

Holdings

1. The ALJ properly considered both supportability and consistency factors in evaluating the state agency consultants' opinions under § 416.920c.
2. The ALJ failed to comply with SSR 96-8p because the RFC did not account for the persuasive limitation that Plaintiff could only adapt to changes that are predictable and introduced gradually.
3. Substantial evidence supports the ALJ's determination that the one-to-two-step instruction limitation was unpersuasive.

Questions Presented

1. Whether the ALJ erred in evaluating the persuasiveness of medical opinions under 20 C.F.R. § 416.920c
2. Whether the ALJ failed to comply with SSR 96-8p by not including persuasive limitations in the RFC assessment
3. Whether substantial evidence supports the ALJ's finding that expert opinions limiting Plaintiff to one-to-two-step instructions were unpersuasive

Disposition

reversed_and_remanded