Unreported / Non-Citable
Background
Myrna B. J. challenged the denial of Social Security benefits, arguing that the administrative law judge mishandled physical impairments, medical-opinion evidence, and mild mental limitations when determining residual functional capacity—the work activities she could still perform.
The parties sought summary judgment on the administrative record.
The Court’s Holding
The court granted Myrna B. J.’s motion, denied the Commissioner’s motion, and remanded for a new hearing. The administrative law judge must properly evaluate the supportability and consistency of the relevant medical opinion and reconsider the physical impairments.
The court also held that mild mental limitations found during the disability analysis could not simply disappear from the residual-functional-capacity assessment. Those limitations must be considered and explained on remand.
Key Takeaways
- Even non-severe mental impairments may affect residual functional capacity.
- An ALJ must explain medical-opinion supportability and consistency with record citations.
- Step-two findings must be carried through the remaining disability analysis.
- The case returns for a new hearing and evidence-based decision.
Why It Matters
The ruling is important for claims involving several individually modest limitations. Practitioners should ensure that every supported restriction, including mild mental limitations, is addressed in the work-capacity analysis.