Teagen B. v. Commissioner of Social Security

Summary

The United States District Court for the Western District of New York reviewed the denial of Teagen B.'s applications for disability insurance benefits and supplemental security income. The court held that the administrative law judge failed to adequately assess and articulate the persuasiveness of medical opinions under the applicable Social Security regulations, and remanded the matter for further administrative proceedings.

Holdings

1. The ALJ failed to comply with the Commissioner's regulations because he did not clearly articulate how persuasive he found the functional portions of the opinions from NP Fulgham and the co-authored opinion from NP Fulgham and MHC St. Laurent.
2. The error was not harmless because the court could not determine from the decision whether the ALJ complied with the substance of the regulations or what role the opinions played in the RFC finding.

Questions Presented

1. Whether the ALJ complied with the Commissioner's regulations by articulating how persuasive he found the medical opinions of NP Daijha Fulgham and the co-authored opinion of NP Fulgham and MHC Chelsea St. Laurent.
2. Whether the ALJ's failure to explain the role of those opinions in the RFC assessment was harmless.
3. Whether remand for further administrative proceedings was required.

Disposition

remanded