David A. M. v. Acting Commissioner of Social Security

Summary

The United States District Court for the Western District of Washington reversed and remanded the Acting Commissioner of Social Security’s denial of Disability Insurance Benefits. The court held that the ALJ did not sufficiently develop the record regarding whether the plaintiff’s past work as an inventory clerk, including light-duty work, required kneeling, crawling, or crouching, which were prohibited by the RFC. On remand, the ALJ was directed to hold another hearing and obtain additional testimony concerning the physical requirements of the past work.

Holdings

1. The ALJ erred by finding that plaintiff could perform his past inventory clerk work as actually performed without determining whether kneeling, crawling, or crouching were part of the physical requirements of his light-duty work.
2. The ALJ's finding that plaintiff could perform his past relevant work as actually performed was not supported by substantial evidence.

Questions Presented

1. Whether the ALJ adequately developed the factual record and made sufficient findings to determine that plaintiff could perform his past relevant work as an inventory clerk as actually performed despite an RFC completely prohibiting kneeling, crouching, and crawling.
2. Whether the ALJ's step-four finding was supported by substantial evidence.

Disposition

reversed_and_remanded