Cheryl C. v. Commissioner of Social Security

Summary

The United States District Court for the Western District of New York grants Plaintiff Cheryl C.'s motion for judgment on the pleadings and denies the Commissioner's motion in an action seeking review of the denial of Disability Insurance Benefits and Supplemental Security Income. The court holds that the Administrative Law Judge failed to explain why he did not incorporate a consultative examiner's opinion that Plaintiff should avoid pulmonary irritants and allergens into the residual functional capacity assessment. The case is remanded for further administrative proceedings.

Holdings

1. The ALJ erred by finding Dr. Magurno's opinion persuasive while omitting her limitation that Plaintiff should avoid pulmonary irritants and allergens from the RFC and failing to explain the omission.
2. The step-five determination was not supported because the hypothetical presented to the vocational expert did not include the full limitation to avoid pulmonary irritants and allergens or the specific triggers identified in the medical opinion.
3. The court could not accept post hoc rationalizations offered by Defendant's counsel to support the ALJ's decision.

Questions Presented

1. Whether the ALJ erred by adopting an RFC limitation that was narrower than a medical opinion the ALJ found persuasive without explaining the discrepancy.
2. Whether the vocational evidence supported the step-five finding when the hypothetical did not include the full environmental limitations described by the consultative examiner.
3. Whether the court could affirm based on post hoc explanations offered by Defendant's counsel.

Disposition

remanded