Marnie W. v. Frank Bisignano, Commissioner of Social Security

Summary

This Report and Recommendation addresses Marnie W.’s challenge to the Commissioner of Social Security’s denial of disability insurance benefits. The magistrate judge concludes that substantial evidence does not support the administrative law judge’s residual functional capacity assessment, particularly regarding the evaluation of medical opinions and the claimant’s statements about her symptoms and daily activities. The recommendation is to reverse the Commissioner’s decision and remand the case under the fourth sentence of 42 U.S.C. § 405(g).

Holdings

1. An ALJ must consider the regulatory factors for medical opinions and must explain how the ALJ considered supportability and consistency, including the medical source's supporting explanations. The ALJ failed to satisfy those requirements when evaluating the opinions of Dr. Scott and Dr. Lanford.
2. An ALJ must consider all relevant evidence bearing on the claimant's symptoms, including daily activities, and must provide legally adequate reasons supported by substantial evidence for discounting the claimant's statements. The ALJ failed to do so here.
3. The ALJ's residual-functional-capacity determination was not supported by substantial evidence because the decision did not provide an accurate and logical bridge between the evidence and the conclusions concerning medical opinions and symptoms.

Questions Presented

1. Whether the ALJ properly evaluated the supportability and consistency of the medical opinions under 20 C.F.R. § 404.1520c.
2. Whether substantial evidence supported the ALJ's residual-functional-capacity assessment.
3. Whether the ALJ adequately evaluated Marnie's subjective symptoms and functional limitations, including her daily activities, under 20 C.F.R. § 404.1529.
4. Whether the Commissioner's denial of disability insurance benefits should be reversed and remanded under sentence four of 42 U.S.C. § 405(g).

Disposition

reversed_and_remanded