ALJ has duty to bridge evidence to conclusion, says court
Wednesday, July 8, 2020

ALJ has duty to bridge evidence to conclusion, says court

By Payroll and Entitlements Editorial Staff

SSA guidance provides that an ALJ’s decision must contain specific reasons for the weight given to a treating source’s medical opinion, supported by the evidence in the record, and must be sufficiently clear. Here, the claimant argued that the ALJ failed to provide good reasons for giving his treating psychiatrist’s opinion limited weight. The court agreed, concluding that the ALJ failed to make her reasoning sufficiently specific to make it clear to subsequent reviewers. The ALJ’s decision ignored facts highly relevant to the issues of the case. In addition, the error was not harmless. The vocational expert’s (VE) testimony refuted the district court’s conclusion that even if the ALJ had given the opinion greater weight it would not have resulted in a more restrictive residual functional capacity determination. Specifically, the VE stated that a hypothetical individual like the claimant who missed work two or more times per month or required a break every two hours would not be employable. Finally, the court dismissed the Commissioner’s argument that any error was one of decision drafting and had no impact on the outcome of the case. The court reasoned that the failure to adhere to SSA regulations was more than a drafting error, it was a legal error. The judgment of the district court was reversed and the case was remanded for further administrative proceedings and for reconsideration of the claims (Eric Lucus v. Commr., CA-8, No. 18-3285, 6/3/2020).

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