Eric G. B. v. Frank Bisignano, Commissioner of Social Security

Summary

The United States District Court for the Western District of Virginia reviewed the denial of Eric G. B.'s application for Social Security disability benefits. The court held that substantial evidence did not support the Administrative Law Judge's determination that Eric was not disabled and vacated the Commissioner's decision, remanding for further development. The court rejected the claimant's challenges concerning his shoulder impairment, treating physician's opinion, subjective allegations, and ability to sustain full-time work in the portions provided.

Holdings

1. The ALJ's residual-functional-capacity assessment was legally deficient because it did not address whether Eric's pain, fatigue, need to change positions, and need to lie down would affect his ability to perform sustained work activities on a regular and continuing basis.
2. Substantial evidence supported the ALJ's assessment of Eric's left shoulder impairment and the limitation to occasional overhead reaching; remand was not warranted on that issue.
3. Substantial evidence supported the ALJ's finding that Dr. Farmer's opinions regarding sedentary work, cane and brace use, and restrictions on standing and walking were unpersuasive.
4. Substantial evidence supported the ALJ's evaluation of Eric's subjective allegations.

Questions Presented

1. Whether substantial evidence supported the ALJ's assessment of Eric's left shoulder impairment.
2. Whether substantial evidence supported the ALJ's evaluation of the opinions of treating physician James Farmer, M.D.
3. Whether substantial evidence supported the ALJ's evaluation of Eric's subjective allegations.
4. Whether the ALJ adequately assessed Eric's ability to perform sustained work activities on a regular and continuing basis, defined as eight hours per day and five days per week or an equivalent schedule.

Disposition

reversed_and_remanded