Jimmy Friese v. Frank Bisignano

Summary

The United States District Court for the Western District of Pennsylvania reviews an ALJ's denial of Jimmy Friese's applications for disability insurance benefits and supplemental security income. The Court denies the Commissioner's motion for summary judgment and grants Friese's motion insofar as he seeks remand, concluding that the ALJ inadequately explained the rejection of medical opinions concerning Friese's ability to perform detailed tasks and interact socially. The matter is remanded for further administrative proceedings under sentence four of 42 U.S.C. § 405(g).

Holdings

1. The ALJ must explicitly address a medical opinion's consistency with the other evidence in the record, but need not explicitly compare that opinion with every other medical opinion.
2. The ALJ's rejection of the opinions limiting Plaintiff to one- to two-step tasks was not supported by substantial evidence because the cited daily activities did not demonstrate an ability to carry out detailed instructions.
3. The ALJ's rejection of the opinions of Drs. Chiodo and Berger concerning Plaintiff's social limitations was not supported by substantial evidence.

Questions Presented

1. Whether the ALJ was required to explicitly compare the consistency of each medical opinion with every other medical opinion in the record.
2. Whether substantial evidence supported the ALJ's rejection of the opinions of Drs. Brelsford and Williams concerning Plaintiff's limitation to one- to two-step tasks.
3. Whether substantial evidence supported the ALJ's rejection of the opinions of Drs. Chiodo and Berger concerning Plaintiff's social limitations.
4. Whether the ALJ should provide supplemental explanation for differing RFC limitations concerning interaction with the public, coworkers, and supervisors.

Disposition

remanded