April H. v. King

Background

April H. sought judicial review of the Social Security Administration’s denial of her applications for disability insurance benefits and supplemental security income. The administrative law judge found that she had several severe mental impairments, including bipolar disorder, generalized anxiety or panic disorder, substance use disorder, post-traumatic stress disorder, and major depressive disorder.

The administrative law judge determined that April H. could perform a full range of work at all physical exertion levels, subject to mental and social restrictions. Those restrictions included simple instructions and routine tasks, no fast-paced production requirements, low-stress work, limited interaction with coworkers and supervisors, no transactional interaction with the public, no teamwork or tandem tasks, and work focused on things rather than people. Based on vocational-expert testimony, the judge found that she could not return to her past work as a sandwich maker but could perform other jobs, including laboratory equipment cleaner, laundry worker, or router.

April H. challenged the residual functional capacity, meaning the most work she could perform despite her impairments. She argued that the administrative law judge found a moderate limitation in her ability to understand, remember, and apply information but did not include that limitation in the residual-functional-capacity finding. The Commissioner argued that the administrative law judge’s decision was supported by substantial evidence.

Analysis

The court concluded that the administrative law judge’s finding of a moderate limitation was not merely a reference to the separate mental-impairment ratings used earlier in the disability analysis. The judge had specifically stated that April H. was more limited in understanding, remembering, and applying information than the consulting psychologists had found.

The court held that the residual functional capacity, which stated only that April H. could understand, carry out, and remember simple instructions, did not adequately account for the moderate limitation. The administrative law judge also did not explain why the limitation was not reflected in the residual functional capacity. Because of that unexplained inconsistency, the court could not meaningfully review the disability decision.

The court further determined that the record did not establish an undisputed entitlement to benefits. It therefore declined to recommend an immediate award of benefits and instead concluded that further administrative proceedings were appropriate.

Recommendation and procedural status

The Report and Recommendation recommends that April H.’s request for relief be GRANTED, that the Commissioner’s request for relief be DENIED, and that the case be REMANDED to the Social Security Administration under sentence four of 42 U.S.C. § 405(g) for further administrative proceedings consistent with the recommendation.

The document states that it is a magistrate judge’s Report and Recommendation, not a final order or judgment of the District Court. It says the parties may file written objections within the time allowed by the applicable local rule.