Gregory C. v. Commissioner of Social Security

Background

Gregory C. sought judicial review under 42 U.S.C. § 405(g) of the Commissioner of Social Security’s final decision denying his application for Title II benefits. He filed his application on June 30, 2022. The Social Security Administration denied it initially and on reconsideration. After a hearing on April 5, 2024, an administrative law judge denied the application on June 10, 2024. The Appeals Council denied Gregory C.’s request for review on September 26, 2024.

Gregory C. moved for summary judgment, and the Commissioner filed a cross-motion for summary judgment.

Issue

Gregory C. raised one issue: whether the administrative law judge’s assessment of his physical residual functional capacity was supported by substantial evidence. Residual functional capacity means the work-related activities a person can perform on a sustained basis. Gregory C. argued that the administrative law judge failed to fully develop the record before making that assessment.

Court’s Analysis

The court explained that an administrative law judge has a duty to develop the record fully and fairly when the evidence is ambiguous or inadequate for proper evaluation. The court found that this duty was not satisfied because the record contained no medical opinion addressing Gregory C.’s physical functions.

At the initial and reconsideration stages, state-agency consultants found that there was too little or insufficient evidence to assess Gregory C.’s physical functional capacity. The remaining medical opinions addressed mental functions, which were not at issue. The court therefore concluded that the administrative law judge had determined Gregory C.’s physical abilities—such as lifting, reaching, standing, walking, sitting, climbing, balancing, stooping, kneeling, and crawling—by interpreting raw medical evidence without the benefit of a medical opinion about physical capability.

The court acknowledged that Gregory C. did not attend a consultative examination in December 2022 and that the administrative law judge kept the record open after the hearing. But the court found that these facts did not resolve the lack of a medical opinion concerning physical residual functional capacity. The court clarified that the administrative law judge was not required to obtain a medical opinion that exactly matched the final residual-functional-capacity finding. The problem was making the physical assessment without any medical opinion about Gregory C.’s physical capabilities.

The court did not identify an error in the mental residual-functional-capacity assessment or in the weighing of Gregory C.’s testimony because those matters were not challenged.

Disposition

The court GRANTED Gregory C.’s motion for summary judgment and DENIED the Commissioner’s cross-motion for summary judgment. It remanded the case for further proceedings. On remand, the administrative law judge must properly develop the record and evaluate the evidence under applicable law consistent with the order.