Summary
The United States District Court for the Western District of North Carolina reviewed the denial of Winnie Cheung’s applications for Social Security disability benefits. The court held that the administrative law judge failed to adequately address Cheung’s alleged urinary frequency and the potential functional effects of Lasix, including the need for restroom breaks. The court reversed the Commissioner’s decision and remanded the matter for further proceedings under sentence four of 42 U.S.C. § 405(g).
Topics
Practice areas
Questions Presented
- Whether the ALJ's residual functional capacity assessment was supported by substantial evidence when the ALJ acknowledged Cheung's alleged medication-related urinary frequency but did not determine its credible frequency or explain why no restroom-break limitation was included.
- Whether the court needed to address Cheung's remaining arguments concerning frequent bathroom breaks and the alleged failure to account for mental impairments after finding remand required on the medication-side-effects issue.
Holdings
- The ALJ erred by failing to analyze the frequency and duration of Cheung's alleged medication-related restroom needs and by failing either to include a corresponding limitation in the residual functional capacity or explain why such a limitation was unnecessary. That omission created an analytical gap preventing meaningful judicial review and required reversal and remand.
Key quotations
“The ALJ must build an “accurate and logical bridge” from the evidence to the conclusions reached—something that did not occur here.” (Section IV)
“Under the substantial-evidence standard, a court looks to an existing administrative record and asks whether it contains sufficient evidence to support the agency’s factual determinations.” (Section III)
Factual background
Cheung alleged disability based on physical impairments including a history of atrial fibrillation, obesity, osteoarthritis, hypocalcemia, and hypothyroidism status post surgery. She testified that Lasix, a cardiac medication, caused urinary frequency requiring restroom use approximately every 15 to 20 minutes or every hour for six hours after taking the medication. The ALJ found that Cheung could perform light work with specified restrictions and concluded at step five that she could perform other jobs existing in significant numbers in the national economy. The administrative record also included vocational-expert testimony that bathroom-break disruptions resulting in 10 percent or more off-task time would preclude competitive employment.
Procedural history
Cheung applied for disability insurance benefits and supplemental security income, alleging disability beginning July 14, 2021. Her claims were denied initially and on reconsideration. After a hearing, an administrative law judge denied the claims on January 31, 2024, and the Appeals Council denied review on March 7, 2025. Cheung timely sought review in the district court, which reversed the Commissioner's decision and remanded under sentence four of 42 U.S.C. § 405(g).
Remand instructions
The matter is remanded to the ALJ for a new hearing and further proceedings consistent with the order. The ALJ must evaluate the frequency and duration of Cheung's restroom needs, assess the credibility and functional impact of the alleged medication side effect, and either incorporate an appropriate limitation into the RFC or explain why no limitation is warranted.