The 7th Circuit Court of Appeals has found that an administrative law judge failed to properly assess a woman’s residual functional capacity in deciding whether she qualified for disability insurance benefits from the Social Security Administration. The judges ordered the case back to the agency for further proceedings.
In Laenise Arnett v. Michael J. Astrue, commissioner of Social Security, No. 11-2424, Laenise Arnett appealed the denial of disability insurance benefits. Arnett applied for DIB in June 2004, claiming her onset date of June 14, 2002. She suffers from numerous physical and mental health issues, including obesity, peripheral vascular disease, chronic obstructive pulmonary disease, depression, and anxiety. She is able to stand for less than two hours a day and has trouble walking more than a few steps at a time.
When evaluating her residual functional capacity, the administrative law judge didn’t mention several of her physical and mental impairments and found that she could perform sedentary work that was limited to carrying up to 10 pounds occasionally, and less than 10 pounds frequently; sitting for six hours of an eight-hour day; walking for two hours of the eight-hour day; and alternating between sitting and standing throughout the day.
The 7th Circuit found problematic that the ALJ didn’t incorporate adequately Arnett’s mental impairments into the RFC and that he didn’t take into account several of Arnett’s diagnosed physical impairments or her obesity. The judges agreed with Arnett that the ALJ failed to formulate a RFC that is sufficiently specific as to how often she must be able to sit and stand.
They remanded the case to the agency for further proceedings.