Decided: June 16, 2016
The Fourth Circuit reversed and remanded the administrative law judge’s decision.
In 2007, George Monroe filed for disability insurance benefits (DIB) and supplemental security income (SSI) for problems related to uveitis that started in December 2006. Monroe’s applications were denied initially and following reconsideration in 2008, Monroe requested a hearing before an administrative law judge (ALJ). Following the hearing, the ALJ denied the application as well. In 2011, the Appeals Council examined Monroe’s request for review, vacated the ALJ’s decision, and remanded to another ALJ for a new decision that would determine specific issues. The Appeals Council also noted that Monroe had filed for DIB and SSI claims in 2010 and the second ALJ’s decision would put all the files together to address all of Monroe’s claims. The second ALJ’s hearing determined that Monroe was not disabled from 2006 through the date of the decision in 2012. Monroe filed a complaint in district court where a magistrate judge recommended that the district court deny Monroe’s motion to grant benefits. The district court followed the magistrate judge’s recommendation of denial and Monroe appealed.
Monroe’s argued on appeal that the ALJ committed legal errors when analyzing the record. The Plaintiff’s first argument was the second ALJ erred in not giving great weight to the first ALJ’s findings regarding the Plaintiff’s severe impairments in the now-vacated 2010 decision. The court disagreed with the Plaintiff’s first argument based on the court’s interpretation of Lively v. Secretary of Health and Human Servs., 820 F.2d 1391, 1392 (4th Cir. 1987) stating that SSA must give such findings as evidence and only need to give it the appropriate weight in light of all relevant facts and circumstances when adjudicating a follow up disability claim involving a unajudicated period. Based on this interpretation, nothing indicates that findings in prior non-final decisions are entitled to any weight; therefore the second ALJ did not err in reviewing Monroe’s application de novo. The court agreed with the Plaintiff’s argument that the ALJ erred by not using a function-by-function analysis to determine his RFC. By expressing Monroe’s RFC first and then concluding the limitations caused by Monroe’s impairments were consistent with that RFC, the ALJ made the error of overlooking limitations and restrictions that narrowed the ranges of work that Monroe may be able to do. For example, while the ALJ determined that Monroe had sleep apnea and narcolepsy, the ALJ never made any specific findings about whether Monroe’s impairments would cause him to experience loss of consciousness that would require breaks from work. Instead, the ALJ simply concluded that Monroe was capable of light work and that Monroe’s claimed symptoms were not credible to the extent they are inconsistent with the RFC the ALJ identified. The court stated that on remand the ALJ would need to consider Monroe’s narcolepsy and sleep apnea and all Monroe’s other impairments to determine on a function-by-function basis how they affect his ability to work. The court also told the ALJ on remand to give a more specific explanation of the ALJ’s reasons for the differing weights he assigned to various medical opinions. The court reversed the district court’s judgment and remanded with instructions to vacate denial of Monroe’s application for benefits and remand for further administrative proceedings.
Ryan Jones