Brandon B. v. Commissioner of Social Security

Summary

The United States District Court for the Western District of New York reviewed the Commissioner of Social Security’s denial of Brandon B.’s application for disability insurance benefits. The court held that the administrative law judge failed to adequately explain the supportability and consistency factors when evaluating medical opinions under 20 C.F.R. § 404.1520c. The court granted the plaintiff’s motion in part, denied the Commissioner’s motion, and remanded the matter for further administrative proceedings.

Holdings

1. The ALJ failed to adequately articulate the supportability factor when evaluating the persuasiveness of MHC Fisk and NP Coggiola's joint medical opinion.
2. The ALJ failed to adequately explain the supportability and consistency of Dr. Domanowski's June 16, 2020 opinion.
3. The ALJ did not commit reversible error by failing to analyze Dr. Domanowski's statement that Plaintiff was fully disabled and unable to work as a medical opinion.

Questions Presented

1. Whether the ALJ complied with 20 C.F.R. § 404.1520c by adequately explaining the supportability and consistency of the medical opinions of Mental Health Counselor Staphanie Fisk and Nurse Practitioner Peter Coggiola.
2. Whether the ALJ adequately evaluated the supportability of Dr. Sydney Domanowski's June 16, 2020 medical opinion.
3. Whether the errors in evaluating the medical opinions required remand for further administrative proceedings.

Disposition

reversed_and_remanded