Sheila T. v. Frank Bisignano, Commissioner of Social Security Administration

Summary

The court reversed and remanded the Commissioner of Social Security’s decision denying Sheila T.’s application for Title II disability insurance benefits. The court held that the Administrative Law Judge failed to properly consider the claimant’s fibromyalgia under Social Security Ruling 12-2p, including the condition’s waxing and waning symptoms and related pain and fatigue limitations. The court did not reach the claimant’s remaining arguments concerning the residual functional capacity assessment and mental restrictions.

Holdings

1. The ALJ committed reversible error by failing to take into account the unique features of fibromyalgia in evaluating Plaintiff's claim, running afoul of SSR 12-2p, requiring reversal and remand.

Questions Presented

1. Whether the ALJ erred in failing to consider Plaintiff's fibromyalgia diagnosis in accordance with SSR 12-2p
2. Whether the ALJ's residual functional capacity finding was supported by substantial evidence
3. Whether the ALJ failed to account for Plaintiff's mental restrictions

Disposition

reversed_and_remanded