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Keywords

hearingmotionsummary judgmentcase lawmotion for summary judgment
defendanthearingmotionsummary judgmentadministrative lawmotion for summary judgment

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Read v. Commissioner, Social Security, Not Reported in Fed. Supp., 2016 WL 2610117

Facts

Dairha Jane Read filed applications for disability benefits on March 5, 2012, claiming a disability onset date of April 29, 2011. Her applications were denied initially and upon reconsideration. A hearing was held on July 29, 2014, where the ALJ found that Ms. Read suffered from severe impairments including degenerative disc disease, migraine headaches, bipolar disorder, PTSD, and ADHD, but determined she retained the residual functional capacity to perform sedentary work. The ALJ concluded that there were jobs available in the national economy that Ms. Read could perform, leading to a denial of her claim for benefits.

Ms. Read protectively filed her applications for benefits on March 5, 2012, alleging a disability onset date of April 29, 2011. Her applications were denied initially and on reconsideration. A hearing was held in her case on July 29, 2014. After the hearing, the Administrative Law Judge (“ALJ”) issued an opinion denying benefits.

Issue

Did the ALJ properly assess Dairha Jane Read's residual functional capacity in light of her limitations in concentration, persistence, and pace?

Did the ALJ properly assess Dairha Jane Read's residual functional capacity in light of her limitations in concentration, persistence, and pace?

Rule

The court must uphold the Commissioner's decision if it is supported by substantial evidence and if proper legal standards were employed, as established in 42 U.S.C. §§ 405(g), 1383(c)(3) and relevant case law.

This Court must uphold the Commissioner's decision if it is supported by substantial evidence and if proper legal standards were employed.

Analysis

The court found that the ALJ's analysis of Ms. Read's limitations in concentration, persistence, and pace was insufficient. Although the ALJ acknowledged moderate difficulties in these areas, the RFC assessment did not adequately address how these limitations affected Ms. Read's ability to perform work tasks over an eight-hour workday. The court referenced the Fourth Circuit's decision in Mascio v. Colvin, which emphasized the need for a more thorough analysis when discrepancies exist between the ALJ's findings at step three and the RFC assessment.

In light of the finding of moderate limitations, under Mascio, more analysis is required to justify the lack of an RFC limitation addressing concentration and persistence.

Conclusion

The court recommended that the Commissioner's motion for summary judgment be denied, the decision of the Commissioner be reversed in part, and the case be remanded for further proceedings.

For the reasons set forth above, I respectfully recommend that the Court DENY Defendant's Motion for Summary Judgment, [ECF No. 17]; REVERSE IN PART the decision of the Commissioner; REMAND the case to the Commissioner under sentence four of 42 U.S.C. § 405(g) for further proceedings in accordance with this Report and Recommendations.

Who won?

Dairha Jane Read prevailed in the case as the court recommended remanding her case for further proceedings, indicating that the ALJ's decision was not adequately supported.

I recommend that the Commissioner's motion be denied, the decision of the Commissioner be reversed in part, and the case be remanded pursuant to sentence four of 42 U.S.C. § 405(g).

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