L. N. D. v. Frank Bisignano, Commissioner, Social Security Administration

Summary

This Report and Recommendation addresses judicial review of the Social Security Administration’s denial of disabled widow’s benefits to the plaintiff. The magistrate judge recommends reversing and remanding because the administrative law judge inadequately explained the evaluation of treating provider Taylor Lewis’s medical opinion concerning the plaintiff’s brittle type 1 diabetes and recurring hypoglycemia and hyperglycemia. The recommendation does not address the plaintiff’s remaining claims of error.

Holdings

1. The ALJ failed to adequately explain or support the finding that Lewis's opinion was not supported by her treatment notes because the ALJ did not identify the treatment records purportedly inconsistent with the opinion and mistakenly attributed a consultative examination to Lewis.
2. The ALJ failed to adequately explain or support the finding that Lewis's opinion was inconsistent with Plaintiff's treatment history and other substantial evidence.
3. The Commissioner's decision should be reversed and remanded for further administrative proceedings because the court could not follow the ALJ's reasoning regarding Lewis's opinion and the error was more than merely technical.

Questions Presented

1. Whether the ALJ adequately evaluated the supportability and consistency of Taylor Lewis's medical opinion under 20 C.F.R. § 404.1520c.
2. Whether the ALJ's rejection of Lewis's opinion was supported by substantial evidence and adequately explained.

Disposition

reversed_and_remanded