RENÉE MARIE BUMB, District Judge.
This matter comes before the Court upon an appeal by Plaintiff George Matchett from a denial of social security disability benefits on September 9, 2016, which was upheld by the Appeals Council on December 6, 2017. [Record of Proceedings, "R.P.", p. 1-7]
For the reasons set forth below, the Court vacates the decision of the Administrative Law Judge ("ALJ") and remands for proceedings consistent with this Memorandum Opinion and Order's reasoning.
When reviewing a final decision of an ALJ with regard to disability benefits, a court must uphold the ALJ's factual decisions if they are supported by "substantial evidence."
In addition to the "substantial evidence" inquiry, the court must also determine whether the ALJ applied the correct legal standards.
The Social Security Act defines "disability" as the inability "to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than twelve months." 42 U.S.C. § 1382c(a)(3)(A). The Act further states,
42 U.S.C. § 1382c(a)(3)(B).
The Commissioner has promulgated a five-step, sequential analysis for evaluating a claimant's disability, as outlined in 20 C.F.R. § 404.1520(a)(4)(i-v). In
The Court recites only the facts that are necessary to its determination on appeal, which is narrow.
Plaintiff was born in 1952, and was 51 years old at the alleged onset date. [R.P., p. 74-75]
A disability hearing was held on February 10, 2016. The ALJ heard testimony from Plaintiff and the Vocational Expert. The administrative record also contains medical records documenting Plaintiff's ailments. Among other things, Plaintiff's medical records reflect diagnoses of adjustment disorder and major depressive disorder. [Ex. 5F, 8F, 9F]
The ALJ concluded that "the claimant was not disabled under sections 216(i) and 223(d) of the Social Security Act through March 31, 2007, the last date insured." [R.P., p. 61] The ALJ found at step two of the five-step sequential analysis that Plaintiff's adjustment disorder and "major depressive disorder, single episode, severe with psychotic features" were severe impairments. [R.P., p. 51] The ALJ proceeded to conclude that Plaintiff did not meet the requirements of any listed impairment, and then determined Plaintiff's residual functional capacity. Relevant to the instant appeal, the ALJ limited Plaintiff "to work. . . that requires no interaction with the public and only occasional interaction with co-workers, with such interaction limited to a brief, superficial basis." [R.P., p. 54] Importantly, the residual functional capacity determination is silent as to Plaintiff's ability to interact with supervisors.
Plaintiff argues that the ALJ's residual functional capacity determination is not supported by substantial evidence because it does not fully and adequately incorporate the medical evidence concerning Plaintiff's "interpersonal difficulties." [Appeal Brief, Dkt #9, p. 21] Plaintiff asserts that there is no evidentiary basis for the disparity between strictly limiting Plaintiff's interactions with the public and co-workers on one hand, and, on the other hand, placing no restrictions at all on Plaintiff's interactions with supervisors.
In response, the Commissioner asserts that "there is no evidence to support Plaintiff's suggestion that he could not interact with supervisors." [Opposition Brief, Dkt #12, p. 20]
The Commissioner is incorrect; there is evidence to support Plaintiff's contention that Plaintiff could not interact with supervisors. Indeed, such evidence was discussed and "given significant weight" by the ALJ in her written decision. [R.P., p. 57] Specifically, the ALJ discussed the opinion of clinical psychologist Carol Schober, writing: "Dr. Schober noted [claimant's] social functioning was limited by his low mood and anxiety. She expressed the opinion that . . . in a work setting [the claimant] would not be able to interact appropriately with the public, co-workers, and supervisors unless it was a very supportive environment where he could work independently and separate himself from others when he needed to." [Id., emphasis added]
The ALJ's decision does not explain why the residual functional capacity determination omits any limitation on interactions with supervisors, even when the ALJ expressly gave "significant weight" to the evidence that "in a work setting [the claimant] would not be able to interact appropriately with the public, co-workers, and supervisors." [R.P., p. 57]
Moreover, the record suggests that such omission could have been outcome determinative in this case. The Vocational Expert testified that, while he could "find jobs that are not working with the public and isolate yourself pretty much from coworkers," the same could not be said for supervisors. [R.P., p. 109] He explained: "[w]ith supervisors, I can't [find jobs]. Supervisors interact when they want to and the person can interact. They aren't usually going to be able to maintain full-time employment." [Id.]
"The Third Circuit has held that access to the Commissioner's reasoning is [] essential to a meaningful court review."