Sara R. v. Kijakazi

Background

The court reviewed Magistrate Judge Tony N. Leung’s report and recommendation. The report recommended that Sara R.’s motion for summary judgment be granted in part and denied in part, that the Commissioner’s motion for summary judgment be denied, and that the case be remanded to the Commissioner under sentence four of 42 U.S.C. § 405(g) for further proceedings. Neither side objected to the report.

Issue and analysis

The report concluded that the Administrative Law Judge erred by failing to explain why the residual functional capacity assessment—which describes the work-related limits the claimant can still perform—restricted Sara R. to occasional interactions with supervisors but did not include a separate limit to brief and superficial social interactions.

The report explained that an occasional-interaction limit addresses the quantity or frequency of interactions, while a brief-and-superficial limit addresses their quality or nature. Because the Administrative Law Judge did not adequately explain the distinction, the report directed the Commissioner to address the state agency psychological consultants’ opinions, explain why the brief-and-superficial limitation was not included in the residual functional capacity assessment, or explain how the assessment otherwise accommodated that limitation.

Because neither party objected, Judge Menendez reviewed the report for clear error. The court found no error, clear or otherwise.

Disposition

The court accepted the report and recommendation. It granted in part and denied in part Sara R.’s motion for summary judgment, denied the Commissioner’s motion for summary judgment, and remanded the matter to the Commissioner under sentence four of 42 U.S.C. § 405(g) for further proceedings consistent with the report and recommendation. The court directed that judgment be entered accordingly.