Brenda L. Edwards v. Frank Bisignano, Acting Commissioner of Social Security

Summary

The United States District Court for the Western District of Pennsylvania reviews Brenda L. Edwards’s appeal from the denial of Widow’s Insurance Benefits under the Social Security Act. The court grants Edwards’s motion for summary judgment, denies the Commissioner’s cross-motion, vacates the benefits denial, and remands under sentence four of 42 U.S.C. § 405(g). The remand is based on the ALJ’s failure to sufficiently develop and explain the record concerning Edwards’s seizure history, brain surgeries, lobotomy, and potential cognitive effects.

Holdings

1. The ALJ adequately evaluated the supportability and consistency of PA Wood's opinion under the revised Social Security regulations, and the rejection of that opinion was supported by substantial evidence.
2. The ALJ failed to develop the record and failed to adequately explain how Edwards's history of seizures, lobotomy, and other brain surgeries affected—or did not affect—her memory and concentration. The administrative decision therefore could not be meaningfully reviewed and had to be vacated and remanded.

Questions Presented

1. Whether the ALJ adequately evaluated the supportability and consistency of the July 2023 mental residual functional capacity opinion of physician's assistant Shelbie Wood.
2. Whether the ALJ failed to develop the record and adequately explain the treatment of Edwards's seizure history, lobotomy, other brain surgeries, and possible resulting memory and concentration impairments.

Disposition

vacated