Joshua H. v. Commissioner of Social Security Administration

Summary

The United States District Court for the Western District of Virginia reviews a Social Security Administration decision denying Joshua H. disability insurance benefits. The court concludes that the administrative law judge did not adequately explain how the claimant’s moderate limitations in concentrating, persisting, or maintaining pace were incorporated into the residual functional capacity assessment. The court remands for further consideration of that issue and does not reach the claimant’s challenge to the evaluation of a psychological consultant’s opinion.

Holdings

1. When an ALJ identifies moderate limitations in concentration, persistence, or pace, the ALJ must either account for those limitations in the RFC or explain why additional RFC limitations are unnecessary. The ALJ's restrictions to simple, repetitive work, occasional interaction with the public and coworkers, and occasional workplace changes did not adequately address or explain the claimant's moderate concentration, persistence, and pace limitations.
2. Remand is required when the ALJ's RFC analysis does not permit the reviewing court to determine whether the denial of benefits was consistent with governing law and regulations.

Questions Presented

1. Whether the ALJ adequately accounted for Joshua's moderate limitations in concentrating, persisting, and maintaining pace in the residual functional capacity assessment.
2. Whether the ALJ's use of restrictions to simple, routine tasks, occasional interaction with others, and occasional workplace changes adequately explained the mental limitations found at step three.
3. Whether the ALJ adequately evaluated the medical opinion of Dr. Susan Belyea.

Disposition

remanded