Louis S. v. Dudek (D.N.J. Apr. 9, 2025) - definition of medical source, need to address medical opinions, medium work RFC, RFC - ALJ’s lay interpretation of the record, subjective symptoms

Louis S. v. Dudek, No. 2:24-CV-08107-MEF (D.N.J. Apr. 9, 2025) (Decision by U.S. District Judge Michael E. Farbiarz)

Briefs for purchase: Plaintiff’s Brief and remand order

Topics addressed:

• Definition of a medical source opinion

• Medical opinions – need to address

• RFC – medium work

• RFC – reliance on outdated assessments of the State agency medical consultants

• RFC – lack of support for findings

• RFC – reliance on ALJ’s lay interpretation of the record

• Subjective symptoms – mischaracterization of record 

• Harmless error 

Rulings addressed:

• Social Security Ruling 83-10 

• Social Security Ruling 96-8p 

Issues briefed:

1)  The ALJ committed reversible error in failing to address the assessment of PT McIntosh.

2)  The ALJ’s finding that Louis S. can perform the exertional demands of medium work is not supported by substantial evidence.

3)  The RFC finding is the product of a lay evaluation and is not supported by substantial evidence.

4)  The ALJ’s reasons for not crediting Louis S.’s subjective complaints are not supported by substantial evidence.

Court decision:

After Plaintiff briefed the merits, the Commissioner chose not to defend the ALJ’s decision and instead, sought a voluntary remand. The parties negotiated the remand terms and the court remanded for further proceedings.